Privacy, Data Protection & AML/CTF Policy
One Agency Elite Property Group (ABN 12 345 678 910)
Last Updated: 10 July 2025
1. Purpose and Scope
This Policy explains how One Agency Elite Property Group ("OAEPG", "we", "our", "us") collects, uses, discloses and safeguards personal information in accordance with the Privacy Act 1988 (Cth)—including the Privacy and Other Legislation Amendment Act 2024—and the Australian Privacy Principles (APPs). It also outlines compliance with the Anti‑Money Laundering and Counter‑Terrorism Financing Act 2006 (Cth) (AML/CTF Act) and AUSTRAC Rules, including Tranche 2 reforms effective from 1 July 2026.
This Policy applies to all interactions with OAEPG, including our website oneagencyepg.com.au, communications, events, and services.
2. What Information We Collect
2.1 Personal Information
- Identity and contact details
- Property preferences and transaction information
- Digital interaction data (cookies, analytics, IP)
- Social media handles and public profile data
- Marketing preferences and survey responses
- Any other information you provide
2.2 AML/CTF-Specific Information
- Identity documents (e.g. passport, driver’s licence)
- Beneficial ownership for legal entities
- Source of funds and wealth
- PEP status and sanctions checks
- High-value transaction details
3. How We Collect Information
- Direct interactions (forms, inspections, calls, messages)
- Digital tools (cookies, bots, analytics)
- Social media engagements and forms
- Third parties (identity verifiers, government registries, marketing platforms)
4. Legal Grounds for Processing
- Contract performance or preparation
- Legal compliance (e.g. AML/CTF, property, tax law)
- Legitimate business interests
- Your consent (withdrawable at any time)
5. How We Use Information
- Service delivery: property transactions and customer care
- Marketing: recommendations, alerts, newsletters (opt-out available)
- AML/CTF compliance: verification, reporting, and monitoring
- Security & legal: fraud prevention, legal defence
6. Disclosure of Personal Information
We may disclose to:
- AUSTRAC and regulatory bodies
- Advisers, banks, brokers, insurers
- IT, cloud, analytics and ID verification partners
- Third parties you authorise (e.g. tradespeople)
- International providers (with adequate safeguards)
7. Direct Marketing & Your Choices
You may receive property alerts and offers unless you opt out. Unsubscribe anytime via email, platform settings, or by contacting us directly.
8. Automated Decision-Making
We use AI and algorithms to personalise services and assess risk. For decisions that significantly affect you, we will provide transparency and allow human review in accordance with 2024 Privacy Act amendments.
9. Overseas Disclosure
Data may be processed in New Zealand, the US, Singapore, and the EU under APP 8 with appropriate safeguards.
10. Access, Correction & Deletion
You may request access or correction of your data. If legally possible, we will also delete it upon request. We’ll respond in a reasonable time and explain any refusal.
11. Security & Retention
We use secure practices including encryption, access controls and document destruction. AML/CTF records are retained for at least seven years.
12. Our AML/CTF Compliance Framework
- AML/CTF Compliance Officer
- Annual ML/TF risk assessments
- Documented AML/CTF Program
- Independent program reviews (every 3 years)
- Regular staff training
13. Complaints
Privacy complaints: Please contact us first. If unresolved, lodge a complaint with the Office of the Australian Information Commissioner (OAIC).
AML/CTF tip-offs: We cannot confirm if an SMR has been filed. You may report suspicions directly to AUSTRAC.
14. Changes to This Policy
We may update this policy due to legal, technological or operational changes. The latest version is always on our website. Material changes will be communicated where practical.
15. Contact Us
One Agency Elite Property Group
Phone: (02) 4423 6000
Email: [email protected]