Privacy, Data Protection and AML/CTF Policy
Last Updated 24 February 2026
One Agency Elite Property Group
- Berry Real Estate & Properties Settlement T/A One Agency Elite Property Group Nowra
- ABN: 89 296 050 991
- 112 Kinghorne Street, Nowra NSW 2541
- 02 4423 6000
- Illawarra Rural Holdings Pty Ltd T/A One Agency Elite Property Group Illawarra
- ABN: 87 600 490 837
- 13/60 Terry Street, Albion Park NSW 2527 & 59 Princes Highway, Dapto NSW 2530
- 02 4257 4515
- AAM Delta Pty Ltd T/A One Agency Elite Property Group Shellharbour
- ABN: 33 129 134 158
- 231 Windang Road, Windang NSW 2528
- 02 4296 4444
- Pure Properties Pty Ltd T/A One Agency Elite Property Group Jervis Bay
- ABN: 93 628 506 356
- 3/62 Owen Street, Huskisson NSW 2540
- 02 4441 8880
- Narrawell Pty Ltd T/A One Agency Elite Property Group Ulladulla
- ABN: 59 057 496 714
- 3/113-117 Princes Highway, Ulladulla NSW 2539
- 02 4455 1066
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
- Property inspections, open homes, auctions, and other events
- Communications via email, phone, messaging, events, in-person and
- Services provided to tenants, landlords, buyers, and sellers
2. What Information We Collect
We only collect information that is reasonably necessary for the following purposes:
2.1 Personal Information
- Identity and contact details (name, mailing or street address, phone, email, age, birth date, profession/occupation)
- Property preferences and transaction information
- Digital interaction data (cookies, analytics, IP address)
- Social media handles and public profile data
- Marketing preferences, survey responses and enquiry details
- Any other information you provide directly or indirectly through our representatives, service centre, surveys, or online platforms
Personal information is defined under the Act as any information that can personally identify you, including your name, address, phone, email, and profession or occupation
2.2 AML/CTF-Specific Information
- Identity documents (e.g. passport, driver’s licence)
- Beneficial ownership for legal entities
- Source of funds and wealth information
- Politically exposed person (PEP) status and sanctions checks
- High-value transaction details
2.3 Real Estate and Property Transaction Information
As a real estate agency providing property sales, leasing and management services, we may collect additional personal information reasonably necessary to assess applications, manage properties, and facilitate property transactions.
This may include:
For rental applicants and tenants
- rental application information
- employment and income details
- rental history and references
- identification documents
- affordability and financial capacity information
- emergency contact details
- tenancy database checks where permitted by law
For property owners and landlords:
- ownership and title information
- insurance details
- bank account details for rental payments
- instructions relating to property management
For buyers and sellers
- contract and transaction information
- settlement and conveyancing details
- identity verification information required for property transactions
The specific information collected will vary depending on whether you are a tenant, applicant, landlord, buyer, seller, contractor, or enquiry contact. We only collect information that is reasonably necessary for our business activities and legal obligations.
We will take reasonable care to ensure that the personal information it collects, uses or discloses is accurate, complete and up to date. This is done by
- Collecting information directly from the client wherever possible and confirming details at the time of collection.
- Verifying key information using reliable documents or sources (e.g. ID, supporting documents, references, or official records where required).
- Confirming or updating details during ongoing contact with clients (for example at inspections, lease renewals, sale updates, or when they contact the office).
- Giving individuals the opportunity to review and correct their information and promptly updating records when notified of changes.
- Maintaining clear data entry procedures so information is recorded correctly in our systems.
2.4 Consequences of not providing Personal Information
If you do not provide the personal information we request, one or more of the following may occur:
- We may not be able to assess or process your rental application, property purchase, or other requested services, either fully or at all.
- We may be unable to communicate with you regarding properties, updates, inspections, or other relevant information
- We may not be able to tailor services, advice, or property recommendations to your needs and preferences.
- For marketing or property alert purposes, we may not be able to send you relevant communications.
Providing your personal information is necessary for us to deliver property management, tenancy, and real estate services effectively.
2.5 Why We Collect Personal Information
We collect personal information to:
For Tenants and Applicants:
- Assess and process rental applications and tenancy agreements
- Verify identity, employment, income, and rental history
- Communicate with landlords, references, and tenancy databases where permitted
- Manage ongoing tenancy obligations and maintenance requests
For Property Owners and Landlords:
- Manage properties and tenancy agreements
- Process rental payments and insurance claims
- Communicate about property inspections, repairs, or regulatory compliance
For Buyers and Sellers:
- Facilitate property sales and settlements
- Verify identity and eligibility for property transactions
- Communicate regarding offers, contracts, and conveyancing matters
For Marketing and Communications:
- Send relevant property alerts, newsletters, and offers
- Tailor communications and services to your preferences
- To update our records and keep your contact details up to date
- To answer enquiries and provide information or advice about existing and new products or services
For Compliance and Security:
- Comply with legal and regulatory obligations (e.g., AML/CTF, tax, tenancy, property law)
- Prevent fraud and manage disputes
- Maintain records for audit and regulatory purposes
- To accurately prepare documents and agreements
- To process and respond to any complaints made by you
- To confirm the legal ownership of the property
- Share necessary information with related bodies corporate, contractors, or service providers
2.6 Receipt of Unsolicited Personal Information
If we receive personal information that was not requested:
- If lawful and relevant, we will handle it in accordance with this Policy.
- If not lawful or not relevant, we will securely destroy or de-identify it.
3. How We Collect Information
- Direct interactions (forms, inspections, calls, messages, applications, open homes, surveys)
- Digital tools (email, cookies, chatbots, analytics software, website access)
- Social media engagements and forms
- Publicly available information or any other organisations where you have given your consent
- Third parties (identity verifiers, government registries, marketing platforms, credit and reporting agencies)
- Your representatives (lawyers, accountants, and financial advisers)
- In-person collection (open homes, property inspections, auctions, reception, sign-in sheets, QR registrations). Where this occurs, a collection notice will be displayed or provided at the time of collection, or as soon as reasonably practicable.
We will take reasonable steps to notify you if personal information is collected from third parties.
4. Legal Grounds for Processing
- Contract performance or preparation
- Legal compliance (e.g. AML/CTF, property, tax, and tenancy law)
- Legitimate business interests
- Your consent (withdrawable at any time)
5. How We Use Information
- Service delivery: property transactions, tenancy management and customer care
- Marketing: personalised recommendations, property alerts, newsletters (opt-out available)
- AML/CTF compliance: verification, reporting, and monitoring
- Security & legal: fraud prevention, legal defence, dispute resolution
6. Disclosure of Personal Information
We may disclose personal information to:
- Regulators: AUSTRAC, Office of the Australian Information Commissioner (OAIC) and regulatory bodies
- Advisers and financial institutions: banks, brokers, insurers, legal advisers
- IT, cloud, analytics and ID verification partners, secure property management and customer relationship management platforms used by our business.
- Contractors and service providers: tradespeople, maintenance contractors, strata managers, utility providers and connection services, inspection service providers)
- Third parties authorised by you
- International providers (with adequate safeguards)
- Residential tenancy databases where permitted by law (e.g. TICA)
7. Direct Marketing & Your Choices
We may collect personal information for marketing purposes when you enquire about a property, attend an inspection, register for updates, or otherwise interact with our services.
You may receive property alerts, newsletters, and offers unless you opt out.
- Opt out at any time via email, platform settings, or contacting us directly
- Opt out at any time via email, platform settings, or contacting us directly
8. Automated Decision-Making
We may use AI or automated tools to personalise services or assess risk.
- For decisions that significantly affect you, we will provide transparency and allow human review in accordance with the 2024 Privacy Act amendments.
9. Overseas Disclosure
To provide our real estate services, we may disclose your personal information to related entities and third-party service providers located outside of Australia.
We share data with partners in the Philippines, India, New Zealand, Singapore, the USA, Japan, and the EU. This includes:
- Offshore Staff & Contractors for admin/operations), accounting/property management and general support our business functions.
- Data Hosting & IT: Your information is hosted on third-party servers which may be located overseas.
We take all reasonable steps to ensure these recipients handle your data in a manner consistent with the Australian Privacy Principles (APPs) through:
- Contractual Obligations: Mandating the same level of security and confidentiality required under Australian law.
- Security Controls: Implementing strict cyber and physical access restrictions.
By providing your personal information to us, you consent to its transfer, storage, and handling outside Australia as described in this policy.
You may withdraw this consent by contacting us in writing. Please note that withdrawing consent may limit our ability to provide certain services (such as processing tenancy applications) where offshore support is essential to our workflow.
10. Access, Correction & Deletion
You have the right to request access to any personal information we hold about you. To do so, please contact us using the details in Section 15 – Contact Us.
Accessing Your Information:
Where we hold information you are entitled to access, we will provide it in a suitable form, such as by email or post.
Limitations on Access
- In some circumstances, we may be unable to grant access. This may occur if access would:
- Interfere with the privacy of others; or
- Breach confidentiality or legal obligations.
- If we refuse access, we will provide you with the reasons for the refusal.
Correcting Your Information:
- If you believe that any personal information we hold about you is inaccurate, incomplete, or outdated, you may request that we amend it.
- We will assess whether the amendment is necessary.
- If we do not agree to make the amendment, we will attach a note to the personal information stating that you disagree with it
You can submit a request to access or correct your information by submitting the following form: Request for Access or Correction of Personal Data
This ensures your personal information is accurate, complete, and up to date, in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.
11. Security & Retention
We retain personal information only for as long as reasonably required for business, legal, regulatory, and dispute-resolution purposes, including tenancy records, property transaction records, and compliance documentation.
Other personal information is retained only as long as reasonably required for legal, regulatory, business, or dispute resolution purposes
We use secure practices including encryption, access controls and document destruction. Access to personal information is restricted to authorised personnel who require the information to perform their duties. AML/CTF records are retained for at least seven years.
11.1 Tenancy Applications
Auto-withdrawal of Applications:
- We use secure practices including encryption, access controls and document destruction. Access to personal information is restricted to authorised personnel who require the information to perform their duties. AML/CTF records are retained for at least seven years.
- You may reuse your Rental Profile or re-enable access to a withdrawn application at any time. Doing so resets the automated withdrawal and deletion timelines.
Sensitive Documents and Data:
- Sensitive documents such as identification (driver’s licence, passport) are automatically deleted 60 days after submission.
- Sensitive data (e.g., passport numbers) are hashed to protect your identity and privacy.
- You may re-upload documents at any time, which will trigger the automated retention cycle again.
Application Deletion Timeline:
- Full rental applications are automatically deleted 18 months after submission.
- For South Australian applicants, applications are deleted 6 months after submission, in line with local requirements.
- Approved applications are securely stored in our purpose-built property management CRM, with access restricted to authorised personnel, for the duration of the tenancy or as required by law.
Handling of Paper / Manual Applications:
- Any physical tenancy applications are scanned into the Snug App or CRM system.
- Once scanned and verified, physical copies are securely destroyed to minimise unnecessary retention of sensitive information.
Overseas Access:
- No sensitive personal information is downloaded from the platform by offshore staff unless the application is approved.
- Approved information may be processed overseas by authorised staff or service providers, in accordance with Section 9 – Overseas Disclosure.
11.2 Marketing Database Retention
- Personal information collected for marketing purposes (e.g., property alerts, newsletters, offers) is retained only as long as necessary to provide these services, or until you opt out.
- Records may be archived or securely deleted after a reasonable period of inactivity (typically 3–5 years).
- All marketing communications include unsubscribe options, and you may opt out at any time via email, platform settings, or by contacting us directly.
11.3 Residential Sales and Property Management – Identity Verification
Purpose of Collection:
- When onboarding new property management clients or facilitating residential sales,
we may collect identification documents (e.g., driver’s licence, passport) to:
- Verify legal ownership of the property
- Comply with legal and regulatory obligations, including AML/CTF and conveyancing requirements
Collection, Handling and Deletion:
- ID documents are collected securely at the point of engagement, either in person, via email, or through digital forms.
- The process is designed to securely delete all data once the verification process has been completed.
- As a failsafe, any documents submitted via digital forms are automatically deleted after 30 days if they have not been manually deleted beforehand.
Overseas Access:
- Where offshore staff or service providers assist with onboarding, no sensitive identification documents are transferred or accessed unless strictly necessary.
- Any access is conducted in accordance with Section 9 – Overseas Disclosure.
This process ensures identity verification for new clients is conducted securely, personal information is protected, and retention is limited to what is legally and operationally required.
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 starr training
13. Complaints
Privacy complaints: If you believe that your privacy has been breached, please contact us using the contact information below and provide details of the incident so that we can investigate it. We will deal with the complaint in accordance with our then current Complaints Handling Procedure.
- The complaint must identify you and be in writing.
- We will investigate your complaint and endeavour to provide a response setting out OAEPG’s decision in writing within 30 days of receipt of your complaint.
- If your complaint remains unresolved, you can 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
AML/CTF tip-offs: We cannot confirm if an SMR has been filed. You may report suspicions directly to AUSTRAC.
15. Contact Us
One Agency Elite Property Group
Phone: (02) 4423 6000
Email: [email protected]