PRIVACY NOTICE
OVERVIEW
The purpose of this policy is to ensure that Belle Property Illawarra manages personal and sensitive information
responsibly, transparently, and in compliance with the Australian Privacy Principles (APPs) under the Privacy Act
1988. This policy outlines how personal information is collected, used, disclosed, stored, and protected by Belle
Property Illawarra.
This policy applies to all personal and sensitive information collected by Belle Property Illawarra in relation to clients,
customers, personnel, contractors, and other stakeholders. It covers all methods of information handling, including
digital, physical, and verbal communications.
Belle Property Illawarra is committed to protecting the privacy of individuals and ensuring the confidentiality,
security, and integrity of personal and sensitive information. The agency will comply with the Australian Privacy
Principles and other relevant legislation while fostering trust and transparency in all interactions.
Belle Property Illawarra complies with the Privacy Act 1988 (Cth) including the 13 Australian Privacy Principles (APPs)
as outlined in the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth). Providing an overall framework
for our privacy practices, Belle Property Illawarra has developed and implemented this APP Privacy Policy.
APPLICABLE LEGISLATION
This policy is designed to maintain requirements with additional jurisdictional requirements including:
- Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth),
- Information Privacy Act 2014 (ACT),
- Privacy and Personal Information Protection Act 1998 (NSW),
AUSTRALIAN PRIVACY PRINCIPLES (APP)
Belle Property Illawarra manages personal information in an open and transparent way. This is evident in the
implementation of practices, procedures and systems we outline in this policy, that ensure our compliance with the
APPs and any binding registered APP code and provide suitable procedures for Belle Property Illawarra personnel to
be able to deal with related inquiries and complaints that may be received from time to time.
The following sections of this policy outline how we manage personal information.
Purpose Of Collection (APP1.4c)
Belle Property Illawarra collects your Personal Information for the primary purpose of providing real estate services
to our clients and marketing. We may also use your Personal Information for secondary purposes closely related to
the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may
unsubscribe from our mailing/marketing lists at any time by contacting us in writing.
When we collect Personal Information, we will, where appropriate and where possible, explain to you why we are
collecting the information and how we plan to use it.
You do not have to provide us with your personal information, however, if you do not, we may not be able to provide
you with our services or information or allow you to any inspect property under our control.
We request the information from you so that we can provide you with the services and products you have requested
from us, and the manage our obligations to you under any customer contract or applicable law. Some of the services
we provide as a real estate agency include: -
o Any service or information we provide acting as an agent for the buying, selling, leasing, managing
properties, or strata complexes:
o Marketing purposes and to provide you with information about products or services that may be of interest
to you
o Enabling us to conduct our business, including meeting any legal or regulatory obligation placed upon us.
We will only collect your sensitive information if you have provided us with consent to do so. Where possible, we will
give you the option of interacting with us anonymously.
-Supervision Guideline 2024 Version 1.0 30 May 2024 Page 73 of 147
The Kinds of Personal Information Collected and Held (APP1.4a)
Belle Property Illawarra collects personal information, which can include: -
- Contact information (name, address, phone number, email).
- Occupation
- Next of Kin (in case of emergency)
- Identification information (driver's license, passport details)
- Financial information (bank account details, income information)
- Rental and Employment references
- Property information (details of properties owned, rented, or being sought)
- Sensitive information such as credit worthiness and other details necessary to assess applications
- Other relevant information (marital status, family details, employment history).
How Personal Information is Collected and Held and Used (APP1.4b; APP1.4c; APP1.4f; APP1.4g)
We only use your personal information for the purpose for which it was provided to us, or
- related purposes that you would reasonably expect, and
- as permitted or required by law.
Such purposes would include: -
a) Internal Use
- In the ordinary course of conducting our business such as
- Assisting you with purchasing, leasing or managing property
- Responding to your enquiries and feedback
- Informing you of property we have for sale or lease or may be open for inspection
- Reporting to vendors or owners of properties that you, may have inspected or made enquiries about
- Providing you with marketing information regarding the services we or third parties acting on our
behalf provide.
- Performing general administration or management functions
- Any other purpose associated with our core function as a real estate agency
We may use the information to contact you by phone, email or text.
b) Disclosure to Third Parties
We may disclose your personal information to related companies, service providers, contractors’ business
partners other parties involved in the transaction, but only if one or more of the following apply:
- You have consented to the disclosure
- You would reasonably expect us to disclose your information this way
- We are authorised by legislation to do so
- Legislation requires us to disclose the information
- If an urgent health emergency or threat to life emergency arises
c) International Disclosure
In some cases, we use third-party service providers who are located, or who store information, outside Australia.
This may include providers of cloud-based software, data storage, IT support, or customer relationship management
systems used in the real estate industry.
Where this occurs, we will take reasonable steps to ensure that any overseas recipient handles your personal
information in a way that is consistent with the Australian Privacy Principles. This includes ensuring that appropriate
privacy and security measures are in place through our contracts and service agreements.
-Supervision Guideline 2024 Version 1.0 30 May 2024 Page 74 of 147
At present, we may disclose or store personal information in the following countries:
Philippines – recognised for strong privacy protections under the Data Privacy Act of 2012 (DPA)
If we engage any additional overseas providers in the future, we will notify you and update this Privacy Policy to
reflect the countries involved.
Automated Decisions
Belle Property Illawarra may use automated decision-making systems for the purposes of:
Assisting with tenant short listing and selection.
Automated decision-making occurs when a computer program or AI is employed to make, or perform an action
substantially related to making a decision. Such a decision may significantly affect your rights or interests. In the
operation of these computer programs, personal information about you may be used to make decisions or take
actions that are directly and substantially related to making those decisions and the services we provide.
As part of this automated decision-making process:
The kinds of personal information used in the operation of such computer programs include name, DOB,
Identification documents (eg: ID, driver’s license, passport), contact details, credit history, salary and
employment information.
The kinds of decisions made solely by the operation of such computer programs or AI may include approval
of application, short listing of application based on affordability criteria.
The kinds of decisions for which a computer program or AI may assist (but not completely decide), that is
substantial and directly related to making the decision, made by the computer program may include
applications, adjusting account settings, denying access, eligibility of service, approval of application, short
listing of application based on affordability criteria.
Belle Property Illawarra ensures that automated decision-making is fair, transparent, and complies with the
Australian Privacy Principles. You have the right to request information about any automated decisions that affect
you and to seek human review of these decisions.
Website Analytics and Cookies
We may use website analytics tools to understand how people use our website, improve our services, and deliver
relevant information or advertising. These tools are provided by third-party vendors, such as Google and others.
How information is collected
Analytics tools may use cookies or other tracking technologies to collect information about your visits, such
as pages viewed, time spent on the site, and device information.
Information collected may include online identifiers like your IP address. When combined with other data,
this may constitute personal information.
Vendors we use
- Google
Purpose of collection
- To monitor and improve website performance
- To provide relevant advertising or marketing information
- To understand user behaviour and preferences
Opting out
- You can opt out of personalised Google advertising by visiting Google Ads Settings or through
YourAdChoices.
-Supervision Guideline 2024 Version 1.0 30 May 2024 Page 75 of 147
Agency responsibility
- We keep this list of analytics providers and opt-out instructions up to date.
- If you do not want to be tracked by our analytics tools, you can disable cookies in your browser or follow the
opt-out instructions above.
Data Security (APP1.4g; APP11)
Belle Property Illawarra has the following data security measures in place to protect your personal information from
unauthorised access, use or disclosure.
All personal information collected by us through our platforms listed is stored in a variety of formats including
electronically in databases, in hard copy files and on personal devices including laptop computers, mobile phones,
cameras and other recording devices.
We take reasonable steps (both technical and organisational) to ensure that your personal information is stored both
securely and is protected by: -
- Having a robust physical security of our premises and database/records/files.
- Taking measures to restrict access to only personnel who need that personal information to effectively
provide services to you
- Having technical measures in place (e.g. anti-virus software, firewalls, the use of a VPN, secure payment
portals, and the use of Secure Sockets Layer (SSL) protocols.
When your Personal Information is no longer needed for the purpose for which it was obtained, we will take
reasonable steps to destroy or permanently de-identify your Personal Information. Unless legislation requires
otherwise, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum
of 7 years, in order that we can meet legislative requirements.
If you are sending us personal information, it is transmitted to us at your own risk. You must take the necessary steps
to protect your information by protecting things like user names and passwords, customer details etc. You should
notify us as soon as practical if you become aware of a security breach.
Data Breaches
If Belle Property Illawarra becomes aware of any security breach, an internal process will be immediately
commenced in accordance with our Data Breach Response Plan. This will guide a conduct of an assessment of the
breach and commence notification and rectification procedures if they are necessary.
Accuracy, Access and Correction of Personal Information (APP1.4d)
It is an important to us that your Personal Information is up to date. Belle Property Illawarra will take reasonable
steps to ensure the information we collect and hold about you is accurate, up-to-date, and complete.
You may access the Personal Information we hold about you and update and/or correct it, subject to certain
exceptions. If you wish to access your Personal Information, please contact us in writing.
If you believe or find that the information we have may not be up to date or is inaccurate, please advise us as soon
as practicable so we can update our records and ensure we can continue to provide a quality service.
Belle Property Illawarra will not charge any fee for your access request but may charge an administrative fee for
providing a copy of your Personal Information that we hold.
So that we may protect your Personal Information, we may require identification from you before releasing the
requested information.
-Supervision Guideline 2024 Version 1.0 30 May 2024 Page 76 of 147
How do I Make Enquiries or Lodge Complaints? (APP1.4e)
If you have an inquiry or complaint relating to our Privacy Policy or compliance with applicable APPs please contact
us using the contact details below. You will need to provide us with sufficient details regarding your complaint, as
well as any supporting evidence and/or information.
We will refer your inquiry or complaint to our Privacy Officer whose details are below. They will, within a reasonable
time, investigate the issue and determine the steps that Belle Property Illawarra will undertake to resolve any
complaints. We will contact you if we require any additional information from you and will notify you in writing of
the response or determination of our Privacy Officer.
If you are not satisfied with our response or determination, you can contact us or raise your concerns with the
Australian Privacy Commissioner via www.oaic.gov.au.
If you believe we have breached the APPs or mishandled your personal information, or you have any questions about
this Privacy Policy, please call immediately us on 02 4228 0888.
Revision of Our Privacy Policy
We may revise this Privacy Policy or any part of it from time to time. Please review this policy periodically for
changes. If We make significant changes to this policy, We may notify you using the contact details provided by you
or by putting a notice on our website www.belleproperty.com/Illawarra.
Your continued use of our website, services, requesting our assistance or the provision of further personal or
sensitive information to us after this Privacy Policy has been revised, constitutes your acceptance of the revised
Privacy Policy.
How to Contact Belle Property Illawarra
Agency Name Belle Property Illawarra
ACN: 147 504 961
Licensee-in-charge Nicole Kay
Address: 46 Harbour Street, Wollongong NSW 2500
Email: Illawarra.info@belleproperty.com
PRIVACY OFFICER Katherine Keaveney
Email: Katherine.keaveney@belleproperty.com
Phone No: 02 4228 0888
OAIC 1300 363 992 or www.oaic.gov.au
