1. Purpose

Taylored Property Co Pty Ltd ("Taylored Property Co", "we", "us", "our") is a specialist residential property management agency based in Glenelg North, South Australia. We manage residential investment properties on behalf of landlords across metropolitan Adelaide under the Residential Tenancies Act 1995 (SA), and we facilitate the sale, purchase and transfer of residential real estate on behalf of clients as a brokered real estate service.

This policy explains how we collect, hold, use and disclose personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), and how we meet our record-keeping obligations as a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act).

2. Scope

This policy applies to personal information we collect about:

•    Landlords and property investors who engage us to manage their property

•    Tenants and prospective tenants

•    Buyers, sellers and prospective buyers and sellers in a real estate sale or purchase we broker

•    Tradespeople, contractors and suppliers we engage

•    Job applicants and any staff or contractors of the business

3. What personal information we collect

Depending on our relationship with you, we may collect:

•    Full name, date of birth, contact details and residential address

•    Identity verification documents (e.g. driver licence, passport, Medicare card) collected for tenancy applications and, where we broker a sale or purchase, for customer due diligence required under the AML/CTF Act

•    Financial information, including bank account details, income and employment information, and rental payment history

•    Property details, lease terms, inspection reports and maintenance records

•    Emergency contact and next-of-kin details

•    Correspondence between you and our team

4. How we collect personal information

We generally collect personal information directly from you — through application forms, our property management system (PropertyMe), REAforms, Eagle Agent, email, phone and in person. We may also collect information from third parties such as referees, previous agents, employers, tradespeople (via Tapi) and, where legally required, identity verification services.

5. Why we collect, use and disclose personal information

We collect, hold, use and disclose personal information to:

•    Assess tenancy applications and manage tenancies

•    Manage properties on behalf of landlords, including inspections, maintenance and rent collection

•    Facilitate the sale or purchase of real estate, including verifying customer identity and meeting our AML/CTF customer due diligence obligations

•    Communicate with landlords, tenants, buyers, sellers and contractors

•    Meet our legal and regulatory obligations, including under the Residential Tenancies Act 1995 (SA), the AML/CTF Act and reporting obligations to AUSTRAC

•    Manage our business operations, including payroll and contractor payments (via Deel)

6. Who we disclose personal information to

We may disclose personal information to:

•    Our staff and contractors who need it to perform their role, including our onshore support (Leah) and our offshore virtual assistant (Yvonne)

•    Tradespeople and contractors engaged through Tapi to carry out maintenance

•    Tenant Options and other referencing or tenancy database services

•    Our payroll and contractor payment provider (Deel)

•    AUSTRAC and other government or regulatory bodies where required or authorised by law

•    Professional advisers, such as our accountant or lawyer, where necessary

6.1 Overseas disclosure

Our offshore virtual assistant, Yvonne, is based in the Philippines. As part of her role she has access to personal information we hold, including tenant, landlord, buyer and seller information. Before disclosing personal information to an overseas recipient, we take reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to the information, in accordance with APP 8. This is supported by written contractual obligations under Yvonne’s Contractor Agreement (Ref TPC-YB-0126), including a confidentiality clause (clause 5), a dedicated data protection clause (clause 6) requiring compliance with both the Data Privacy Act of 2012 of the Philippines and applicable Australian privacy law, and Statement of Work terms requiring client data to be kept confidential, stored only in approved cloud drives, and protected by two-factor authentication (2FA) and VPN.

7. Data security

We take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure. Our current measures include multi-factor authentication (MFA) on our core business systems and a password manager with enforced strong, unique passwords for all staff and contractors. Further detail is set out in our Information Security Policy.

8. Data quality, access and correction

We take reasonable steps to ensure the personal information we collect, use and disclose is accurate, up to date and complete. You may request access to, or correction of, the personal information we hold about you by contacting us using the details in section 11.

9. Retention and destruction

We retain personal information for as long as reasonably necessary for the purposes it was collected, and in accordance with our legal obligations. Where personal information is collected in connection with a designated service under the AML/CTF Act (i.e. a brokered real estate sale or purchase), we retain the relevant records for at least seven (7) years, as required by the AML/CTF Act. Where information is no longer required and we are not legally required to retain it, we take reasonable steps to destroy it or ensure it is de-identified.

10. Complaints

If you believe we have breached the Australian Privacy Principles, you may lodge a complaint using the contact details below. We will investigate and respond within a reasonable timeframe. If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

11. Contact us

Taylored Property Co Pty Ltd

1A Alison Street, Glenelg North, SA 5045

Attention: Skye Taylor, Director

Phone: (08) 7118 2011

Email: skye@taylored.property