APP 13 does not set a number for correction the way people expect, and the operative standard is reasonable steps in the circumstances , which is sensitive to what the information is doing. The practical scale for a conveyancing practice: Information in active use in a live matter , for example a misspelt name on documents about to be lodged, or a wrong figure going to the revenue office: immediately. APP 10 is engaged as well as APP 13, and the cost of the error grows with every party it reaches. Information in a closed file : promptly, in the ordinary course. A refusal : give the written notice rather than letting it drift, because an unanswered correction request is what turns into a complaint. The pattern across enforcement is consistent and worth internalising: what escalates is rarely the original error. It is the handling of the person who pointed it out.

How does a conveyancer correct wrong client information?

Q: Do we have to tell anyone else we corrected it?

Only if asked, and then usually yes. APP 13.1(b)(ii) is the on-request trigger for correcting. APP 13.2 is the part practices miss, and it is headed "Notification of correction to third parties" : where you correct information you had previously disclosed to another APP entity, and the individual requests that you notify that entity, you must take reasonable steps to do so unless it is impracticable or unlawful . In a conveyancing matter the previous recipients are rarely a short list: the other side's representative, the lender, the electronic lodgment network, the revenue office, the titles authority, the agent. Which is why the disclosure note we recommend on the sharing page earns its keep. If you do not know who you sent it to, you cannot discharge APP 13.2, and reconstructing it from a matter file under time pressure is the expensive version. Note the two limits , because they release you in real cases: the obligation is to take reasonable steps, and it does not apply where notification would be impracticable or unlawful . Notifying a party you can no longer identify or reach is not required. Neither is a notification that would breach another obligation.

Where you are satisfied the information is inaccurate, out of date, incomplete, irrelevant or misleading, APP 13 requires you to take reasonable steps to correct it, and that duty runs whether or not anyone asks. If the client asks, you also have to consider notifying the third parties you previously disclosed it to. The conveyancing-specific wrinkle is the identity record: you correct a client's current details, but you do not rewrite the historical record of what you verified and when.

By Jon Oates, Founder of Privaproof · Last updated 28 July 2026

‹ Conveyancer privacy compliance hub

General information, not legal advice. Your obligations depend on your circumstances.

When do we have to correct something?

Two triggers, and the first one surprises people because it does not require a request.

APP 13.1 requires you to take such steps as are reasonable in the circumstances to correct personal information you hold, having regard to the purpose for which it is held, to ensure it is accurate, up to date, complete, relevant and not misleading. That applies where you are satisfied it needs correcting, or where the individual requests it.

So if you discover mid-matter that a client's name is recorded incorrectly, or that a file note records something that turned out to be wrong, the obligation is already engaged. Waiting to be asked is not the standard.

APP 10 sits behind it and runs in the same direction: you must take reasonable steps to ensure the personal information you collect is accurate, up to date and complete, and that what you use or disclose is, having regard to the purpose, accurate, up to date, complete and relevant.

For a conveyancing practice, APP 10 is the more consequential of the two on any given day, because the whole transaction runs on the accuracy of names, entities and figures that you pass to the lender, the revenue office and the land titles authority.

Sources: Privacy Act 1988 (Cth), APP 10, APP 13.1, APP 13.2 · OAIC APP 13 guidelines

Can we change a VOI or AML record?

Correct the client's current details. Do not rewrite the record of what you verified at the time.

This is the one genuinely conveyancer-specific answer on this page, and it resolves an apparent conflict rather than choosing a side.

An identity verification record is a record of a past event: these documents were produced, on this date, and this is what they showed. Its evidentiary value comes entirely from being an accurate account of that event. Editing it later so it reads the way things are now does not correct it, it falsifies it, and it damages the audit trail the AML/CTF record-keeping obligation exists to preserve.

So the correct mechanism is to add, not overwrite:

Where the client's circumstances have changed, for example a name change on marriage, record the new information and the evidence for it. The original verification record stays as it was, describing what was verified then.
Where the historical record itself is wrong, for example a transcription error in a licence number, annotate the correction with the date and the reason rather than silently amending the field. The correction is then visible and dated, which is what both regimes want.
Where the client disputes what you recorded and you are not satisfied it is wrong, APP 13.4 gives you the answer below.

⚠️ Stated as sound practice rather than as a rule, deliberately. Part 10 of the AML/CTF Act requires customer due diligence records to be retained for seven years, and we have not found a provision that expressly dictates how an existing record must be amended. The annotate-rather-than-overwrite approach follows from what a verification record is for, not from a section we can cite at you. It is the safer habit either way, because a dated annotation satisfies both regimes while a silent edit satisfies neither.

Sources: Privacy Act 1988 (Cth), APP 13; Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) record-keeping obligations · See also how long a conveyancer keeps records

Do we have to tell anyone else we corrected it?

Only if asked, and then usually yes.

APP 13.1(b)(ii) is the on-request trigger for correcting. APP 13.2 is the part practices miss, and it is headed "Notification of correction to third parties": where you correct information you had previously disclosed to another APP entity, and the individual requests that you notify that entity, you must take reasonable steps to do so unless it is impracticable or unlawful.

In a conveyancing matter the previous recipients are rarely a short list: the other side's representative, the lender, the electronic lodgment network, the revenue office, the titles authority, the agent. Which is why the disclosure note we recommend on the sharing page earns its keep. If you do not know who you sent it to, you cannot discharge APP 13.2, and reconstructing it from a matter file under time pressure is the expensive version.

Note the two limits, because they release you in real cases: the obligation is to take reasonable steps, and it does not apply where notification would be impracticable or unlawful. Notifying a party you can no longer identify or reach is not required. Neither is a notification that would breach another obligation.

Sources: Privacy Act 1988 (Cth), APP 13.1, APP 13.2 · OAIC APP 13 guidelines

What if we disagree that it is wrong?

You are not obliged to accept a client's account, and there is a defined route for the disagreement.

If you refuse to correct, APP 13.3 requires you to give the individual written notice setting out the reasons for the refusal, except to the extent it would be unreasonable to do so, and the complaint mechanisms available. (Compilation 104, `verify/2026-07-30-app12-13-subsections.md`)

And APP 13.4 is the provision worth knowing. Where you refuse, and the individual requests it, you must take reasonable steps to associate with the information a statement that they consider it to be inaccurate, out of date, incomplete, irrelevant or misleading, in a way that will make the statement apparent to users of the information.

That is a good outcome for a practice, not a bad one. It means a factual disagreement does not have to be won. The record carries both accounts, anyone reading it sees both, and nobody has to certify a version they do not believe.

APP 13.5(b) puts it beyond doubt: you must not charge the individual for making the request, for correcting the information, or for associating the statement. (Compilation 104, `verify/2026-07-30-app12-13-subsections.md`)

Sources: Privacy Act 1988 (Cth), APP 13.3, APP 13.4, APP 13.5 · OAIC APP 13 guidelines

What about information that is already on the title or lodged?

This is where clients most often ask for something you cannot give, so it is worth saying clearly.

APP 13 obliges you to correct information that you hold. It does not give you power over another organisation's records, and it does not reach the land titles register, the revenue office's records or a lender's systems. Those have their own correction processes under their own legislation, and a mistake in a lodged instrument is a conveyancing problem with a conveyancing remedy, not a privacy one.

What APP 13 does do in that situation is APP 13.2. Correct your own record, and where the client asks, take reasonable steps to notify the parties you disclosed the incorrect information to. That is often the practical route by which the downstream record gets fixed, even though the fixing itself happens under other rules.

Being clear with the client about which lever is being pulled saves a complaint. "We have corrected our record and told the lender" is an accurate and useful answer. "We have corrected the title" would not be.

Sources: Privacy Act 1988 (Cth), APP 13.1, APP 13.2 · OAIC APP 13 guidelines

How quickly?

APP 13 does not set a number for correction the way people expect, and the operative standard is reasonable steps in the circumstances, which is sensitive to what the information is doing.

The practical scale for a conveyancing practice:

Information in active use in a live matter, for example a misspelt name on documents about to be lodged, or a wrong figure going to the revenue office: immediately. APP 10 is engaged as well as APP 13, and the cost of the error grows with every party it reaches.
Information in a closed file: promptly, in the ordinary course.
A refusal: give the written notice rather than letting it drift, because an unanswered correction request is what turns into a complaint.

The pattern across enforcement is consistent and worth internalising: what escalates is rarely the original error. It is the handling of the person who pointed it out.

Sources: Privacy Act 1988 (Cth), APP 10, APP 13.1, APP 13.4 · See also what happens if a conveyancer does not comply

This is general information, not legal advice. Privaproof provides privacy tools and general information; it is not a law practice and does not provide legal advice, and it does not assess your AML/CTF obligations, which are administered by AUSTRAC. Privaproof's conveyancer materials are self-authored and are not independently reviewed by a solicitor.