Privacy Policy

Saltwater Property Management (ABN 66 691 852 749) (“we”, “us” or “our”) provides property management services in Queensland. We respect your right to privacy and are committed to safeguarding the privacy of our customers, clients, tenants, and website visitors.

We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APP) which regulate the collection, use, and disclosure of personal information. This policy sets out how we collect and treat any person who provides us with personal information in any form or by any means (“you” or “your”) personal information.

We reserve the right to review and if necessary, change this Privacy Policy. We will post changes to this Privacy Policy on our website.

Compliance and Auditing

This Privacy Policy governs all personal information collected by and provided to us and must be adhered to by all persons who access, use, process, control or otherwise deal with personal information on our behalf. This Policy applies to independent contractors and job applicants, as well as individuals who provide us with personal information.

What is Personal Information?

Personal information is any information or an opinion about you that can be used to identify you, whether true or not, and no matter how the information or opinions are recorded. The information may be collected from you directly or provided to us by another party.

Why Do We Collect Personal Information?

We collect personal information from you for the following primary purposes:

  • To allow us to lawfully carry out our property management functions and activities in Queensland, including meeting our obligations under the Residential Tenancies and Rooming Accommodation Act 2008 (Qld).
  • To enable us to deliver the products and services that you requested (e.g., managing your property, assessing a tenancy application).
  • To provide you with further information about the products and services you requested.
  • To help us review, manage and enhance our services.
  • To communicate more effectively with you.
  • For administration purposes, including charging, billing and collecting debts.
  • To promote and market our products and services which we consider may be of interest to you.
  • When considering making offers to job applicants and prospective employees or for employment purposes; and
  • To receive services from you or the organisation which employs you.

We may also collect, hold, use and/or disclose personal information if you consent or if required or authorised under Australian or Queensland law.

What Personal Information do we Collect?

We collect personal information that is reasonably necessary for one or more of our functions or activities.

The type of information that we collect and hold may depend on your relationship with us. For example:

  • Property Owners/Clients: Your name, address, email address, contact telephone number, financial details, property details, and bank account information.
  • Prospective and Current Tenants: Your name, address, email address, contact telephone number, employment history, tenancy history, references (including previous property managers/owners), proof of identity (e.g., driver’s licence, as permitted by law), emergency contact, and financial ability to pay rent. We will adhere to the restrictions in the Residential Tenancies and Rooming Accommodation Act 2008 (Qld) regarding the collection of personal information during the rental application process.
  • Candidates Seeking Employment: Your name, address, email address, contact telephone number, employment history, references, resume, and payment details.
  • Suppliers/Contractors: Your name, address, email address, contact telephone number, business records, billing information, and information about goods and services supplied.

We will only collect sensitive information where you consent to the collection of the information and the information is reasonably necessary for one or more of our functions or activities. Sensitive information includes, but is not limited to, information or an opinion about racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, membership of a trade union, sexual preferences, criminal record, health information or genetic information.

If you feel that the personal information that we are requesting at any point is not information that you wish to provide, please feel free to raise this with us.

Employee Records

This Policy does not apply to the collection, holding, use or disclosure of personal information that is an employee record, as this is exempt under the Privacy Act.

How do we Collect and Hold Personal Information?

We must collect personal information only by lawful and fair means. We will collect personal information directly from you if it is reasonable or practicable to do so. We may collect personal information in a number of ways, including without limitation:

  • Through application forms (e.g., tenancy applications).
  • By email or other written mechanisms.
  • Over a telephone call or in person.
  • Through transactions.
  • Through our website or social media.
  • From third parties, including through publicly available information sources (e.g., telephone directories, internet, social media sites), and Residential Tenancy Databases.

Unsolicited personal information is personal information that we receive which we did not solicit. Unless we determine that we could have collected the personal information in line with the APPs, or the information is contained within a Commonwealth record, we must destroy the information to ensure it is de-identified.

When do we Disclose your Personal Information?

You acknowledge and agree that we may disclose your personal information for any of the purposes for which it was collected, as indicated under this Policy, or where it is under a legal duty to do so. This may include disclosure in accordance with the Residential Tenancies and Rooming Accommodation Act 2008 (Qld).

Disclosure will usually be internally, to related entities, or to third parties such as:

  • Property owners (for tenant applications/management).
  • Prospective tenants (for viewing/assessing a property).
  • Referrers, referees, and emergency contacts.
  • Contracted service suppliers (e.g., maintenance contractors, tradespeople, body corporate managers, insurance companies).
  • Residential Tenancy Database operators (where permitted by law).
  • Government authorities and regulatory bodies (e.g., RTA, QCAT, ATO, law enforcement).
  • Credit reporting bodies.

Before we disclose personal information about you to a third party, we will take steps as are reasonable in the circumstances to ensure that the third party does not breach the APPs in relation to the information.

Is Personal Information Used for Direct Marketing?

We may use or disclose personal information (other than sensitive information) about you for the purpose of direct marketing (for example, advising you of new properties or services being offered by us). You can opt out of receiving direct marketing communications from us by contacting the Privacy Officer in writing or, where available, by unsubscribing appropriately.

What happens if you do not provide your Personal Information?

You are not obliged to give us your personal information. If you would like to access any of our services on an anonymous basis or using a pseudonym, we will take reasonable steps to comply with your request. However, we will require you to identify yourself if:

  • We are required by Australian or Queensland law to deal with individuals who have identified themselves; or
  • It is impracticable for us to deal with you if you do not identify yourself or elect to use a pseudonym (e.g., it is impossible to process a tenancy application or manage a property without your full contact and identity details).

Please be aware that your request to be anonymous or to use a pseudonym may affect our ability to provide you with the requested services.

Integrity and Security of your Personal Information

We will take such steps as are reasonable in the circumstances to protect the personal information we hold from misuse, interference, loss, and from unauthorised access, modification or disclosure.

Information which we collect will be stored in paper-based files or other electronic record keeping methods in secure databases (including trusted third-party storage providers based in Australia and overseas).

We will maintain physical security over paper and electronic data stores, such as through locks and security systems at our premises, and computer and network security measures (e.g., firewalls, user identifiers, and passwords) to control access to the computer systems.

If we hold personal information and no longer need the information for any purpose for which the information may be used or disclosed, the information is not contained in any Commonwealth record, and we are not required by law to retain the information (e.g., a minimum period under the Residential Tenancies and Rooming Accommodation Act 2008 (Qld)), we will take such steps as are reasonable in the circumstances to destroy the information or to ensure it is de-identified.

Website

When you visit our website, we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

  • Cookies: We may use cookies on our website. Cookies are small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings.
  • Third-party sites: Our site may from time to time have links to other websites not owned or controlled by us. We are not responsible for the privacy practises of other such websites.

Access to and Correction of your Personal Information

  • Access: If we hold personal information about you, you may request access to that information by putting the request in writing and sending it to the Privacy Officer. We will respond to any request within a reasonable period and will not charge you for making a request, though we may charge for the reasonable time and expense incurred in compiling the information.
  • Correction: If we hold personal information that is inaccurate, out-of-date, incomplete, irrelevant or misleading, we must take steps as are reasonable to correct the information. If you make a request in writing to the Privacy Officer to correct the information, we will respond within a reasonable period.

There are certain circumstances in which we may refuse to grant access or correct the personal information. In such situations, we will give you written notice that sets out the reasons for the refusal and the mechanisms available to you to make a complaint.

Complaints

You have a right to complain about our handling of your personal information if you believe we have breached the APPs. If you wish to make such a complaint to us, you should first contact the Privacy Officer in writing.

Your complaint will be dealt with in accordance with our internal procedures, and we will provide a response within a reasonable period.

If you are unhappy with our response to your complaint, you may refer your complaint to the Office of the Australian Information Commissioner (‘OAIC’). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the OAIC website.

How changes are made to this Privacy Policy?

Saltwater Property Management may amend this Privacy Policy from time to time, with or without notice to you. We recommend that you visit our website regularly to keep up to date with any changes.