1. Aim
Real Estate Institute of Tasmania (ACN 009 481 207) (we, our or us) is committed to complying with our obligations under the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles (APPs).
We are committed to respecting your privacy and protecting your personal information. Our staff are trained to protect your personal information in accordance with our policies, procedures and systems.
2. Policy
This policy outlines how we manage and secure your personal information. It also describes the kinds of personal information that we hold and for what purposes, and how that information is collected, held, used and disclosed.
Our services and products include membership with REIT, events, professional development, this website and our applications, documents and other services, including REIT Realforms (Services).
This policy is easy to access and is available on our website at https://reit.com.au/privacy-policy/. You may request a copy of the policy by contacting the Privacy Officer in accordance with paragraph 12.1 of this policy.
Please read this policy carefully before you provide us with any personal information.
We will review this policy from time to time. We encourage you to check our website regularly as any updated policy will be available on our website.
3. Types of information that we collect and hold
3.1 General information
We may collect and hold the following types of personal information about you:
(a) identifiers and contact information such as name, date of birth, residential address, business address, postal address, post code, email address, phone number, occupation, gender, preferences and employment status;
(b) identification documents that contain personal information;
(c) membership information including names of employees;
(d) insurance related information (including, but not limited to, professional indemnity insurance details);
(e) information about how you use and access our Services, including cookies; and
(f) any other information that we consider to be reasonably necessary.
3.2 Sensitive information
We may need to collect sensitive information about you from time to time. Unless the collection of the sensitive information is permitted under the Privacy Act, we will only collect sensitive information with your consent where that information is reasonably necessary for our functions.
3.3 Information required by law
We may collect personal information about you because the collection of the information is required or authorised by law or a court/tribunal order.
3.4 Website activity
We may collect information about your computer hardware and software. This information can include:
- IP address;
- browser type;
- domain names;
- access times; and
- referring website addresses.
3.5 Social media
We may collect information about you when you interact with us through social media channels. Please note that we will only interact with you on confidential matters via a secure forum.
4. Collecting your information
4.1 Collecting personal information
We collect your personal information so that we can perform our functions and activities.
We will, if it is reasonable and practical to do so, collect personal information directly from you.
We may collect your personal information:
(a) through our website(s), including forms and cookies;
(b) through providing our Services, including REIT Realforms;
(c) when you interact with us by email, post, phone, in person or via our website, applications, social media channels or using any other method;
(d) when you subscribe to our mailing list or newsletters;
(e) when you attend our events or professional development sessions;
(f) when you participate in our training sessions or courses; or
(g) when you voluntarily submit your personal information, or request it be provided by a third party, to us for any reason.
4.2 REIT RealForms
(a) This policy applies to data collected through REIT RealForms which is provided pursuant to our REIT Website Terms of Use found here: https://reit.com.au/terms-of-use/.
(b) Our members may use REIT Realforms to prepare contracts or other documents.
(c) REIT RealForms is not owned and operated by us. REIT RealForms is operated by Land Services SA Operating Pty Ltd as trustee for the Land Services Operating Trust, and is provided by way of licence from REI Coinvest Pty Ltd (LSSA).
(d) By providing data to REIT RealForms you are consenting to the collection and processing of your personal information and any personal information of others uploaded by you, by LSSA in accordance with LSSA’s privacy policy which can be found here: https://www.landservices.com.au/privacy/, and by any third parties whose products or services may be integrated into REIT RealForms.
4.3 Collecting personal information from other sources
Sometimes we collect personal information about you from other sources where it is necessary to do so. This may happen where:
(a) you have consented to the collection of the information from someone else;
(b) we are required or authorised by law to collect the information from someone else; or
(c) it is unreasonable or impracticable to collect the information from you personally.
Examples of other sources that we may collect personal information from include, but are not limited to data provided by users to REIT Realforms.
4.4 What happens if you do not provide us with your personal information?
If you do not provide us with your personal information, we may not be able to:
(a) verify your identity; and
(b) provide our Services.
4.5 Notification of collection of personal information
When we receive personal information directly from you, we will take reasonable steps to notify you of the collection and the circumstances that surround the collection.
Sometimes:
(a) we collect your personal information from third parties; or
(b) you may not be aware that we have collected your personal information.
If we collect information that can be used to identify you, we will take reasonable steps to notify you of the collection and the circumstances that surround the collection, unless we are reasonably satisfied the third party has notified you of such collection.
5. Protecting personal information
5.1 Storing personal information
We are committed to keeping your personal information secure.
We store your personal information in different ways, including physical and electronic form.
We take technical measures (as described in clause 5.2) and organisational measures (through this privacy policy and training of staff) to secure your personal information.
We treat all personal information as confidential. We will take reasonable steps to ensure personal information is protected from:
(a) misuse, interference and loss; and
(b) unauthorised access, modification and disclosure.
5.2 How we store your information
Some of the ways we store your information are:
(a) secure hard copy document storage (i.e. storing hard copy documents in locked filing cabinets);
(b) security measures for access to our computer systems;
(c) providing a discreet environment for confidential discussions;
(d) access control for our buildings;
(e) security measures for our websites;
(f) anti-spam, anti-virus and anti-malware software; and
(g) secure server room with access limited to authorised personnel.
5.3 Third party storage of personal information
Personal Information may be stored by third parties, including LSSA. LSSA as operator of REIT Realforms, may store your personal information in cloud storage platforms based from servers located in Australia on the terms and conditions of its privacy policy which can be found here: https://www.landservices.com.au/privacy/.
5.4 What happens if we no longer need your personal information?
If we no longer need your personal information for any purpose, we will take reasonable steps to destroy or permanently deidentify the information, unless:
(a) the information is contained in a Commonwealth record; or
(b) we are required by law, or a court/tribunal order, to retain the information.
6. Purposes for collecting, holding, using and disclosing information
We collect, hold, use and disclose your personal information for the purpose it was collected and related purposes, including:
(a) to enable access to our Services, including access to REIT RealForms;
(b) to facilitate the preparation and processing of contracts and other documents through REIT RealForms as requested by you;
(c) to provide and improve products and/or services associated with the REIT RealForms;
(d) to comply with any applicable laws, regulations or codes of practice; and
(e) for any other purpose for which you have given your consent.
Your personal information may also be used on an aggregated or non-aggregated (but de-identified basis) as permitted by law, in property information products and reports showing market insights, comparisons and trends in sales figures, rental turnover or property attributes and within tools, reports and products for real estate agencies and other commercial businesses for use in their business.
7. Use and disclosure of information
7.1 Use and disclosure of personal information
We will not use or disclose personal information we hold about you that was collected for a particular purpose for another purpose, unless:
(a) you have consented to the use or disclosure of the information for another purpose; or
(b) the use or disclosure is otherwise permitted under the Privacy Act (e.g. you would reasonably expect us to use or disclose the information for another purpose or the use or disclosure of the information is required or authorised by law or a court/tribunal order).
7.2 Disclosure to third parties
Sometimes we may disclose personal information about you to third parties, located in Australia. Examples of third parties that we may disclose your personal information to include, but are not limited to:
(a) LSSA in its capacity as licensee and operator of REIT RealForms;
(b) third party operators of platforms linked to or from REIT RealForms;
(c) any other person where you have given your consent.
7.3 Overseas recipients
We are not likely to disclose your personal information to any overseas recipients.
7.4 Disclosure
Where your personal information is disclosed, we will seek to ensure that information is used, held and disclosed consistently with the Privacy Act and any other applicable laws.
8. Direct marketing
8.1 Direct marketing
We may use or disclose your personal information (excluding sensitive information) for direct marketing purposes.
8.2 Sensitive information
We will only use or disclose your sensitive information for the purposes of direct marketing if you have consented to the information being used or disclosed for the purposes of direct marketing.
8.3 Method of direct marketing
We may conduct direct marketing by sending you marketing messages for general marketing purposes, including choosing and delivering tailored content or advertising to you.
8.4 Opt-out
If at any time you decide you:
(a) do not want to receive any more direct marketing material from us;
(b) do not want us to use or disclose the information for direct marketing in the future; and/or
(c) want to know where we obtained the information,
you may:
(d) contact the Privacy Officer in accordance with paragraph 12.1 of this policy; or
(e) opt-out of receiving any more marketing material via any opt-out mechanism contained in our marketing correspondence.
All our marketing correspondence will display a clearly visible and user-friendly opt-out mechanism. We may imply consent to receive direct marketing material if you do not use the opt-out mechanism.
8.5 Processing requests
If you request to no longer receive direct marketing material we will process your request within a reasonable period after the request is made.
9. Quality of personal information
We will take reasonable steps to ensure that any personal information we collect, use or disclose is accurate, complete, up-to-date and relevant to our functions or activities.
If you believe that your personal information is not accurate, complete or up to date, please contact the Privacy Officer in accordance with paragraph 12.1 of this policy.
10. Access to personal information
10.1 Requesting access
You may at any time request access to personal information we hold about you. We will give you access to that information, unless an exception in the Privacy Act applies.
You can request access to your personal information by contacting our Privacy Officer in accordance with paragraph 12.1 of this policy.
10.2 Dealing with access requests
We will respond to a request for access within a reasonable time (usually 30 days), and give you access in the manner you request, if it is reasonable and practicable to do so.
We may need to verify your identity before we give you access to your personal information.
10.3 Access fees
Depending on the nature of the request, we may charge you a small fee to access that information.
10.4 Refusal to give access
If we refuse to give you access, we will:
(a) take reasonable steps to give you access in a manner that meets our needs as well as yours; and
(b) provide you with the reasons for our decisions as required by the Privacy Act.
11. Correcting personal information
11.1 Requesting correction
If you think that any personal information we hold about you is incorrect, inaccurate, out-of-date, incomplete, irrelevant or misleading, you may request us to correct the information by contacting the Privacy Officer in accordance with paragraph 12.1 of this policy.
11.2 Correcting information
We will take reasonable steps to correct that information.
11.3 Dealing with correction requests
We will respond to a correction request within a reasonable time (usually 30 days).
We may need to verify your identity before we correct your personal information.
11.4 Notification of correction to third parties
If we correct your personal information that we have previously disclosed to another entity, and you ask us to tell the other entity about the correction, we will take reasonable steps to tell the other entity about the correction, unless it is impractical or unlawful to do so.
11.5 Refusal to correct information
If we refuse to correct the personal information, then we will provide you with the reasons for our decision as required by the Privacy Act.
12. Complaints about personal information
12.1 Complaints
If you:
(a) have any issues about the way we handle your personal information after reading this policy;
(b) become aware of a potential breach of privacy; or
(c) wish to make a complaint,
please contact our Privacy Officer.
Complaints can be made in writing or orally to:
Privacy Officer
Telephone: +61 3 6223 4769
Mail: GPO Box 868, Hobart TAS 7001
Email: dustin.crayford@reit.com.au
12.2 External complaint mechanism
If you are not happy with the outcome of the Privacy Officer’s investigation or we have not replied to you within a reasonable time, then you can raise your concern with the Office of the Australian Information Commissioner (OAIC).
Complaints can be made to OAIC in the following ways:
Office of the Australian Information Commissioner
Telephone: 1300 363 992
Email: enquiries@oaic.com.au
Mail: Office of the Australian Information Commissioner
GPO Box 5218 Sydney NSW 2001