Indirect Collection Source Schedule
IPP3A is the rule that applies when an organisation collects personal information about someone from a source other than that person. It is about telling people in plain language when an organisation collects their information indirectly.
Key:
→ means information AMA sends about you to another party
← means information AMA receives from another party.
GBG Cloudcheck Direct
Information exchanged:
→ Client identity data (name, DOB, address, document images)
← Verification result (pass/fail, watchlist and PEP screening outcome)
Purpose: Meet identity verification and compliance requirements
Law basis: Anti-Money Laundering and Countering Financing of Terrorism Act 2009
Notice method: Engagement letter and this schedule
FNZ Limited
→ Client identity data (name, DOB, address, details from a passport, birth certificate or other ID document, bank account number)
← investment holdings
Purpose: Information required by FNZ to hold your investments on their platform
Law basis: Usually not applicable
Notice method: Engagement letter and this schedule
Strategi Limited
→ sharing client files with personal information during a compliance review/check.
← Receiving report that contain or reference client personal information
Purpose: Compliance assurance
Law basis: Usually not applicable
Notice method: This schedule
Financial Services Complaints Limited
→ sharing complaint details with client information;
← receiving client complaint details, submissions, evidence collected from the client
or third parties
Purpose: Complaints and handling and dispute resolution
Law basis: Financial Service Providers (Registration and Dispute Resolution) Act 2008
Notice method: This schedule
Financial Markets Authority
→ sharing client files with personal information during compliance monitoring visit/
information request;
← receiving complaint material, referral information, investigation correspondence,
extracts of client statements or evidence
Purpose: Regulatory supervision; risk identification; enforcement and accountability
Law basis: Financial Markets Authority Act 2011; any applicable law subject to the FMA information request
Notice method: This schedule