Privacy Policy for Beacon Property Management
Effective Date: 24 May 2025
1. About this Privacy Policy
Beacon Property Management ("we", "us", "our") is committed to protecting the privacy of your personal information. We operate as a property management company in South East Queensland, Australia. This Privacy Policy outlines how we collect, use, disclose, and manage personal information in accordance with the Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth) ("Privacy Act"), and other relevant Australian laws, including Queensland legislation such as the Residential Tenancies and Rooming Accommodation Act 2008 (Qld).
This policy applies to our interactions with our clients (property owners/landlords, including those residing internationally), prospective clients, tenants, prospective tenants, individuals whose information we may obtain from third-party data providers, contractors, and any other individuals whose personal information we may collect and use in the course of our business operations.
By providing us with your personal information, engaging with our services, or where we have otherwise lawfully obtained your personal information, you consent to its collection, use, and disclosure in accordance with this Privacy Policy. We will endeavour to manage your personal information in an open and transparent way.
2. What is Personal Information?
"Personal information" means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not. This can include sensitive information (such as health information or criminal records), which is a subset of personal information that is given a higher level of protection under the APPs.
3. Collection of Personal Information
3.1 Types of Personal Information We Collect
We aim to collect only personal information that is reasonably necessary for, or directly related to, one or more of our legitimate functions or activities. The types of personal information we may collect include, but are not limited to:
For Landlords/Property Owners:
Full name, contact details (including phone number, email address, postal address – which may be an international address).
Banking details for the purpose of disbursing rental income and other financial transactions related to the management of the property.
Proof of property ownership and identity.
Tax identification information (e.g., Tax File Number), where required or authorised by law, or with your consent for specific purposes.
Details of the property or properties being managed.
Relevant insurance policy details.
Any other information you voluntarily provide or that is necessary to provide our comprehensive property management services to you.
For Tenants and Prospective Tenants:
Full name, contact details (including phone number, email address, current and previous residential addresses).
Date of birth.
Proof of identity (e.g., driver's license, passport). In line with Queensland law, copies of identity documents for successful applicants will only be retained with explicit consent where legally permissible; otherwise, they will be sighted, verified, and the necessary details recorded. For unsuccessful applicants, such information will be securely destroyed or de-identified within prescribed timeframes.
Employment details and history, and income verification to assess the ability to meet rental obligations.
References from previous landlords, property managers, or employers.
Information from authorised tenancy databases (we will notify you and obtain your consent before accessing such databases).
Banking details for rent payments, bond administration, and any other authorised payments.
Emergency contact information.
Details regarding your tenancy requirements and preferences.
For Contractors, Suppliers, and Service Providers:
Name, business name, contact details.
Australian Business Number (ABN) or Australian Company Number (ACN).
Relevant licenses (e.g., trade licenses) and insurance certifications (e.g., public liability).
Banking details for payment of invoices.
For Direct Marketing and Business Development (including from Third-Party Data Providers):
Name, contact details (phone number, email address, postal address).
Information about property ownership or investment interests.
Other information relevant to identifying potential clients for our property management services or other business offerings.
For General Enquiries or Website Visitors:
Name and contact details if you contact us with an enquiry.
Information collected via cookies or website analytics regarding your usage of our website (please refer to Section 10: Website Usage and Cookies).
We will only collect sensitive information if it is reasonably necessary for our functions or activities, with your explicit consent, or if the collection is required or authorised by law.
3.2 How We Collect Personal Information
We collect personal information through various channels:
Directly from you: When you engage our services, complete forms (e.g., tenancy applications, management agreements), communicate with us in person, over the phone, via email, or through our website or online portals.
From third parties: This may include:
Your authorised representatives (e.g., legal advisor, financial planner).
Tenant databases (subject to your knowledge and consent as required by law).
Previous landlords or property managers (as referees).
Publicly available sources of information (e.g., company registers).
Government agencies (e.g., Residential Tenancies Authority (RTA)).
Third-Party Data Providers and Data Brokers: We may acquire personal information (primarily contact details and property-related information) from reputable third-party data providers or data brokers for the purposes of direct marketing and business development. When we obtain personal information from such sources, we take reasonable steps to ensure that these providers have collected the information lawfully and have obtained any necessary consents for the information to be shared with and used by third parties like us for marketing purposes.
Unsolicited Information: If we receive unsolicited personal information (information we did not request), we will, within a reasonable period, determine whether we could have collected the information under APP 3 if we had solicited it. If we determine that we could not have collected it, and the information is not contained in a Commonwealth record, we will destroy or de-identify the information as soon as practicable, provided it is lawful and reasonable to do so.
3.3 Notification of Collection
At or before the time we collect personal information about you, or as soon as practicable afterwards, we will take reasonable steps to ensure you are aware of:
Our identity and contact details (as set out in Section 13).
The purposes for which we are collecting the personal information.
The main consequences (if any) for you if all or part of the information is not provided.
Any third parties, or types of third parties, to whom we usually disclose personal information of that kind.
Whether we are likely to disclose the personal information to overseas recipients and, if it is practicable to specify, the countries in which such recipients are likely to be located.
The fact that this Privacy Policy contains information about how you may access the personal information about you that we hold and seek the correction of such information.
The fact that this Privacy Policy contains information about how you may complain about a breach of the Australian Privacy Principles, or a registered APP code (if any) that binds us, and how we will deal with such a complaint.
This notification is often provided by directing you to this Privacy Policy.
Where personal information is collected from a third-party data provider for direct marketing purposes, we will take reasonable steps to notify you of the collection and the matters above at or before the time of our first communication with you, or as soon as practicable afterwards, unless doing so would be impracticable or an exception applies under law.
4. Purposes for Collecting, Holding, Using, and Disclosing Personal Information
We collect, hold, use, and disclose personal information for purposes that are reasonably necessary for the proper conduct of our property management business and our legitimate business interests. These purposes include, but are not limited to:
Providing Property Management Services:
Assessing applications from prospective tenants.
Preparing and executing tenancy agreements and other relevant documentation.
Collecting and processing rent payments, bond payments, and other monies.
Disbursing funds to landlords and paying authorised property expenses.
Arranging and overseeing property maintenance, repairs, and inspections.
Communicating effectively with landlords, tenants, occupants, and contractors.
Managing and resolving disputes or legal proceedings related to tenancies or managed properties.
Undertaking marketing and leasing activities for properties.
Complying with our contractual obligations to landlords and tenants.
Business Operations:
Administering our client and business relationships.
Internal accounting, record-keeping, and auditing.
Improving our services, including staff training and system development.
Managing relationships with our suppliers and contractors.
Insurance, risk management, and professional indemnity purposes.
Responding to enquiries, feedback, and complaints.
Legal and Regulatory Compliance:
Complying with our obligations under relevant Australian and Queensland legislation, including (but not limited to) the Privacy Act 1988 (Cth), Residential Tenancies and Rooming Accommodation Act 2008 (Qld), Property Occupations Act 2014 (Qld), and taxation laws.
Cooperating with regulatory bodies such as the RTA, the Office of Fair Trading Queensland, and law enforcement agencies as required or authorised by law.
Direct Marketing and Business Development:
To identify and contact individuals who may be interested in our property management services or other products or services we may offer.
To conduct direct marketing campaigns, including via mail, email, SMS, and telemarketing (cold calling), using personal information collected directly from you or acquired from third-party data providers, subject to legal restrictions (see Section 4.1).
To analyse marketing effectiveness and develop new business opportunities.
Potential Future Sale of Personal Information:
We may, in the future, consider selling certain personal information we hold. This would only occur where we have obtained your explicit, informed consent to do so specifically for the purpose of such a sale to a nominated third party or type of third party, or if the sale is otherwise expressly permitted by law (e.g., as part of a sale of our business assets, subject to confidentiality). General consent to this privacy policy does not constitute consent to sell your personal information. Further specific consent will be sought if this activity is contemplated.
We will not use or disclose your personal information for a purpose other than a purpose for which it was collected (a primary purpose), or a related secondary purpose that you would reasonably expect (or a directly related secondary purpose for sensitive information), unless:
You have consented to the use or disclosure for another purpose.
The use or disclosure is required or authorised by or under an Australian law or a court/tribunal order.
A permitted general situation exists under the APPs (e.g., to lessen or prevent a serious threat to the life, health, or safety of any individual, or to public health or safety).
4.1. Direct Marketing Practices
We are committed to complying with all applicable laws governing direct marketing, including the Privacy Act 1988(Cth), the Do Not Call Register Act 2006 (Cth), and the Spam Act 2003 (Cth).
When conducting direct marketing, including telemarketing, we will:
Ensure that individuals who have opted out of receiving marketing communications from us are not contacted.
Provide a simple means for you to opt-out of receiving further direct marketing communications from us in each communication.
Not make unsolicited telemarketing calls to numbers registered on the Do Not Call Register unless we have your explicit consent to do so or the call is otherwise permitted under the Do Not Call Register Act 2006. (Note: Purchasing a list does not automatically grant such consent).
Ensure any commercial electronic messages comply with the Spam Act 2003.
You can opt-out of receiving direct marketing communications at any time by contacting us (see Section 13) or using the opt-out mechanism provided in the communication.
5. Disclosure of Personal Information
In conducting our business, we may disclose your personal information to various third parties. These parties may include:
Our Landlord Clients: Information regarding tenancy applications, tenant conduct, property condition, and financial matters related to their property will be shared with the landlord (property owner) or their authorised representatives.
Tenants and Occupants: Information relevant to the tenancy and property will be shared as necessary.
Contractors and Service Providers: We engage third-party contractors (e.g., tradespeople, maintenance personnel, smoke alarm compliance services, valuers, debt collection agencies, IT support providers, data storage providers, marketing agencies) to assist us in delivering our property management services. We will only disclose personal information necessary for them to perform their services.
Financial Institutions: For processing rental payments, bond lodgements/refunds, and payments to landlords and creditors.
Insurance Providers and Brokers: In relation to insurance claims or policy management concerning managed properties.
Tenancy Database Operators: We may disclose information to, and collect information from, authorised tenancy databases as permitted by and in accordanceance with the Residential Tenancies and Rooming Accommodation Act 2008 (Qld) and the Privacy Act 1988 (Cth). You will be notified if we intend to list your information on such a database and of your rights in relation to such listings.
Government and Regulatory Bodies: Including the RTA, Queensland Civil and Administrative Tribunal (QCAT), the Australian Taxation Office (ATO), the Office of Fair Trading, and other bodies where required or authorised by law.
Our Professional Advisors: Such as our lawyers, accountants, and auditors, for the purpose of obtaining professional advice.
Marketing and Business Development Partners: Where you have consented, or it is otherwise lawful, we may disclose information to third parties who assist us with our marketing and business development activities.
Third-Party Data Purchasers: In the event we decide to sell certain personal information, and only where we have obtained your prior, explicit, and informed consent specifically for such disclosure and sale to a nominated third party or type of third party, or as part of a sale of our business assets (subject to confidentiality and compliance with applicable laws).
In the event of a sale or transfer of our business, to the potential purchaser or transferee (subject to confidentiality obligations and applicable laws).
Other Parties: As required or authorised by Australian law or a court/tribunal order, or with your express consent.
5.1 Disclosure to Overseas Recipients (International Landlords)
Given that some of our landlord clients may reside internationally, it is a necessary part of our service to disclose personal information (primarily relating to tenants, prospective tenants, the managed property, and financial performance) to these overseas recipients. The countries in which such recipients are likely to be located will vary depending on the individual landlord's country of residence. We will inform you if we are likely to disclose your information to an overseas recipient in a specific country if it is practicable to do so.
By providing your personal information to us (this applies particularly to tenants and prospective tenants whose information may be shared with overseas landlords), you consent to the disclosure of your information to these overseas landlords for the purposes outlined in this Privacy Policy, primarily for the management of the tenancy and the property.
When disclosing personal information to an overseas recipient, APP 8.1 requires us to take reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to the information. However, if you explicitly consent to the disclosure of your personal information to an overseas recipient, and we inform you that as a result of your consent, APP 8.1 will not apply to the disclosure, then we will not be required to take such steps.
You acknowledge that by providing this consent:
We will not be accountable under the Privacy Act 1988 (Cth) if the overseas recipient handles your personal information in a way that breaches the APPs.
You may not be able to seek redress under the Privacy Act 1988 (Cth) or in the overseas jurisdiction for any breach of your privacy by the overseas recipient.
The overseas recipient may not be subject to privacy laws that provide the same level of protection as in Australia.
If you do not consent to the disclosure of your personal information to our overseas landlords, please advise us in writing. However, please note that this may significantly impact our ability to manage the property or your tenancy effectively, and in some cases, we may not be able to proceed with a tenancy or management agreement if this consent is withheld, as communication with the landlord is essential.
We will otherwise only disclose personal information to an overseas recipient if:
We reasonably believe that the recipient is subject to a law or binding scheme that has the effect of protecting the information in a way that, overall, is at least substantially similar to the way the APPs protect the information, andthere are mechanisms you can access to take action to enforce that protection; or
The disclosure is required or authorised by or under an Australian law or a court/tribtribunal order.
6. Data Quality and Security
6.1 Data Quality
We will take such steps as are reasonable in the circumstances to ensure that the personal information we collect is accurate, up-to-date, and complete. We also take reasonable steps to ensure that the personal information we use or disclose is, having regard to the purpose of the use or disclosure, accurate, up-to-date, complete, and relevant. We encourage you to contact us to update any personal information we hold about you.
6.2 Data Security
We take reasonable steps to protect the personal information we hold from misuse, interference, and loss, and from unauthorised access, modification, or disclosure. Our security measures include, but are not limited to:
Implementing physical security for our premises (e.g., locked offices, secure document storage).
Utilising technological safeguards such as firewalls, secure servers, password-protected access to computer systems, and data encryption where appropriate.
Restricting access to personal information to our employees, contractors, and authorised service providers who need it to perform their duties.
Implementing internal policies and procedures regarding data security, staff training on privacy obligations, and responsible information handling practices.
Securely destroying or permanently de-identifying personal information when it is no longer needed for any purpose for which it may be used or disclosed under the APPs, and we are not otherwise legally required to retain it (e.g., in compliance with statutory record-keeping obligations under tenancy and property laws, such as the retention periods specified in the Residential Tenancies and Rooming Accommodation Act 2008 (Qld) and associated regulations).
While we are committed to protecting your personal information, we cannot guarantee the absolute security of any information transmitted to us or by us over the internet. Any such transmission is at your own risk.
7. Access to and Correction of Personal Information
7.1 Access
You have a right to request access to the personal information that we hold about you. To request access, please contact our Privacy Officer using the details provided in Section 13. We will respond to your request within a reasonable period after the request is made (generally within 30 days).
We will provide access in the manner you request if it is reasonable and practicable to do so. We may charge a reasonable fee for providing access to cover our administrative costs (e.g., photocopying, retrieval costs). We will not charge a fee for the making of the request itself.
In certain circumstances, as permitted by APP 12, we may refuse to grant you access to your personal information. If we refuse access, we will provide you with a written notice that sets out the reasons for the refusal (unless it would be unreasonable to do so) and the mechanisms available to complain about the refusal.
7.2 Correction
We take reasonable steps to ensure the personal information we hold about you is accurate, up-to-date, complete, relevant, and not misleading. If you believe that any personal information we hold about you is incorrect, out-of-date, incomplete, irrelevant, or misleading, please contact our Privacy Officer.
We will take reasonable steps to correct the information if we are satisfied that it requires correction, having regard to the purpose for which it is held. We will respond to a correction request within a reasonable period (generally within 30 days). We will not charge a fee for a correction request.
If we correct personal information about you that we have previously disclosed to another entity (that is an APP entity), and you request us to notify that other entity of the correction, we will take such steps (if any) as are reasonable in the circumstances to give that notification unless it is impracticable or unlawful to do so.
If we refuse to correct the information as requested, we will provide you with a written notice that sets out the reasons for the refusal (unless it would be unreasonable to do so) and the mechanisms available to complain about the refusal. You may also request that we associate a statement with the personal information that you believe it to be inaccurate, out-of-date, incomplete, irrelevant, or misleading. We will take reasonable steps to associate the statement in such a way that it will be apparent to users of the information.
8. Anonymity and Pseudonymity
Wherever it is lawful and practicable, individuals have the option of not identifying themselves, or of using a pseudonym, when dealing with us. However, due to the nature of our property management services (which involve legal agreements, financial transactions, and security considerations), and our direct marketing activities, it is generally not practicable for us to deal with individuals who have not identified themselves or who are using a pseudonym. For example, we require personal information to enter into a management agreement with a landlord or a tenancy agreement with a tenant, and to effectively conduct targeted marketing.
9. Mandatory Notifiable Data Breaches
We are committed to complying with the Notifiable Data Breaches (NDB) scheme under the Privacy Act 1988 (Cth). In the event of an "eligible data breach" (i.e., unauthorised access, disclosure, or loss of personal information that is likely to result in serious harm to any of the individuals to whom the information relates), we will notify the Office of the Australian Information Commissioner (OAIC) and affected individuals as soon as practicable, in accordance with our obligations under the NDB scheme. We have procedures in place to assess and respond to potential data breaches.
10. Website Usage and Cookies
When you visit our website ([Insert Your Website Address Here if you have one, otherwise state if not applicable or remove sentence]), we may collect certain non-personally identifiable information such as your browser type, operating system, the website visited immediately before coming to our site, your IP address, and pages accessed on our site. This information is used in an aggregated manner to analyse how people use our site, so that we can improve our services and your experience.
Our website may use "cookies." Cookies are small text files that a website can transfer to an individual's computer hard drive for record-keeping purposes. Cookies can make the use of our website easier by storing information about your preferences on a particular site, enabling you to take full advantage of our services. The use of cookies is an industry standard and many major websites use them. Most internet browsers are pre-set to accept cookies. If you prefer not to receive cookies, you can adjust your internet browser to disable cookies or to warn you when cookies are being used.However, disabling cookies may limit your ability to use certain features of our website.
Our website may contain links to other third-party websites. These links are provided for your convenience only. We are not responsible for the privacy practices or the content of such linked websites. We encourage you to read the privacy policies of any linked websites you visit.
11. Changes to this Privacy Policy
We may review and update this Privacy Policy from time to time to ensure it reflects our current information handling practices, changes in our business, or changes in the law. Any updated versions of this Privacy Policy will be made available on our website (if applicable) or can be obtained by contacting our Privacy Officer. We encourage you to periodically review this policy. Your continued use of our services, provision of further personal information, or use of our website after this Privacy Policy has been updated will be deemed as your acceptance of the revised policy.
12. Complaints and Enquiries
If you have any questions or concerns about this Privacy Policy, our management of your personal information, or if you believe that we have breached the Australian Privacy Principles or any registered APP code that binds us, please lodge a complaint with our Privacy Officer using the contact details below:
Please provide as much detail as possible in your complaint, including the date, time, and circumstances of the matter that you are complaining about, how you believe your privacy has been interfered with, and the outcome you are seeking.
We will:
Acknowledge receipt of your complaint promptly (usually within 5 business days).
Carefully investigate your complaint and determine the steps we will take to resolve it.
Aim to resolve your complaint and provide you with a written response within 30 days of receiving your complaint. If we are unable to resolve the complaint within this period, we will inform you of the reason for the delay and an expected timeframe for resolution.
If you are not satisfied with our response to your complaint, or if you do not receive a response from us within 30 days, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted by:
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
Post: GPO Box 5218, Sydney NSW 2001
Website: www.oaic.gov.au
13. How to Contact Us
For any enquiries regarding this Privacy Policy or our privacy practices, please contact:
Privacy Officer Beacon Property Management [Insert Your Company's Physical Address] [Insert Your Company's Phone Number for Privacy Enquiries] [Insert Your Company's Email Address for Privacy Enquiries]
Disclaimer:
This Privacy Policy is intended to provide a general overview of how Beacon Property Management collects, uses, holds, and discloses personal information. It is current as at the Effective Date stated above. While Beacon Property Management has made efforts to ensure this policy is accurate and reflects its intended practices, including direct marketing using information from various sources and the potential future sale of data subject to explicit consent, it does not constitute legal advice. The laws regarding privacy, direct marketing (including the Do Not Call Register Act 2006 and Spam Act 2003), and property management are complex and subject to change.
The practices of acquiring personal information from data brokers for cold calling and any future sale of personal information carry significant legal obligations and risks. Beacon Property Management is responsible for ensuring its compliance with all applicable laws, including obtaining valid consents where required. This policy outlines our intended approach, but practical adherence to the law is paramount.
Beacon Property Management strongly recommends that individuals and entities with specific concerns or requirements seek independent legal advice. Beacon Property Management does not accept any liability for any reliance placed on this policy without such independent legal advice being sought, or for any actions taken or not taken based on the information provided herein, except to the extent that liability cannot be excluded by law.
While Beacon Property Management takes reasonable steps to protect personal information, we cannot guarantee the absolute security of information. Individuals providing personal information, or whose information is lawfully obtained by Beacon Property Management, are subject to the terms outlined herein.