Effective Date: 26 July 2022
Iris Property Management Pty Ltd (“Iris” or “We”) is a private licenced property manager specialising in share housing. Our tenants come from all aspects of society based upon the principles of diversity, inclusion and equality. We considering a prospective tenant it is important for us to gather personal and sensitive information to ensure the safety and wellbeing of all of our tenants, staff, neighbours and stakeholders. This is our “Purpose” for the collection of information.
1.2. The Privacy Act 1988 (Cth) (Privacy Act) regulates the collection of information by certain organisations. Iris, as an organisation, is not an entity which would ordinarily be required to comply with the Privacy Act or the Australian Privacy Principles.
1.3. However for the convenience of our tenants Iris uses the Centrelink Centerpay service. As a condition of us using this service which we are required to be compliant as a business Privacy Act and the Australian Privacy Principles and therefore this policy is in accordance with those obligations.
1.4. Iris owns and operates a website located at:
We take your security very seriously and have put in place suitable procedures to safeguard the information we collect from the Site and online.
1.5. We may also collect personal information from directly from.
1.6. By doing any of the following:
1.6.1. accessing the Site,
1.6.2. requesting information on, enquiring about, or providing feedback in relation to, our services (online, in writing, by telephone or in person), or
1.6.3. otherwise providing, or consenting to the collection of, personal information by Iris, its officers, agents or employees, after this policy has been brought to your attention,
you acknowledge and consent to the use, collection, storage or disclosure of your personal information by us in accordance with this policy. If you do not agree to us handling your personal information in the manner set out in this policy we will not be able to provide our services to you and you should not provide us with any personal information.
2. What is personal information and what kinds of information do we collect?
We follow the definition of personal information given in the Privacy Act: “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.”
2.1. The kinds of personal information we may collect, hold and process about you depends upon how you interact with us. This information may vary depending on the specific needs of Iris, however, it may include:
2.1.1. your name and contact details (address, email, telephone number etc);
2.1.2. how you interact with us and/or the Site and/or information you enter into or upload to the Site;
2.1.3. your business or associated companies or entities;
2.1.4. messages (including via SMS), emails, voicemail, tenancy application forms and other correspondence and frequency of enquiries as well as comments and feedback and responses to surveys;
2.1.5. your IP address and / or other device identifying data;
2.1.6. other information required to provide a service or information you have requested from us;
2.1.7. sensitive information;
2.1.8. CCTV footage when in attendance at our premises and at common areas at our share house properties;
2.1.9. for the sole purpose of Centrepay, taxation information including protected information, as defined by s201A of the Social Security (Administration) Act 1999 (Cth);
2.1.10. any information relating to you that you provide to us directly (online, in writing, by telephone or in person); and
2.1.11. information about your nominated referee for the purposes of a tenancy application (“Nominated Referees”) (which an applicant may provide) such as their names, contact information, occupation status and occupation position for the purpose of conducting reference check and by providing this information to us you warrant that you have obtained prior consent of your Nominated Referee. (any comment made by a Nominated Referee is treated as their personal information and therefore confidential to them).
2.2. We may retain information provided by prospective tenants to help assess any further applications they may make. For the avoidance of doubt, just because you were not accepted once does not necessarily preclude you from acceptance later.
3. Why do we collect your personal information?
3.1.1. providing you with our services or information about our services and activities;
3.1.2. to promote and drive engagement with our services;
3.1.3. sending communications you request or contacting you and responding to your enquiries;
3.1.4. providing third parties (for example property maintenance contractors) with information about you and your activities to assist us in providing the services;
3.1.5. cooperating with law enforcement bodies and government agencies where required by law or the terms of any relevant licence or industry code of practice;
3.1.6. communicating with you and providing you with information about your use of the services;
3.1.7. ensuring consistency of service across our business and other internal business purposes;
3.1.8. assessing a tenancy application, including suitability of an applicant as a tenant in a share house environment, conducting reference checks with Nominated Referees, appropriately managing compliance of our lease agreement and house rules
3.1.9. developing or refining our services and activities as well as tailoring our services; and
3.1.10. internal business and corporate purposes, corporate governance, auditing and record keeping.
3.2. Our use of personal information may extend beyond the uses described above but will be restricted to purposes that we consider to be related to our functions and activities.
3.3. But we want to make clear, we do not collect personal information for the purpose of “selling” it as data.
4.1. Our tenants come from all aspects of society based upon the principles of diversity, inclusion and equality. We considering a prospective tenant it is important for us to gather personal and sensitive information to ensure the safety and wellbeing of all of our tenants, staff, neighbours and stakeholders
4.2. When gathering sensitive information we are committed to doing so in a respectful and non-judgemental way. We accept tenants from all backgrounds, cultural, ethnicities and circumstances, but in some instances our service may not be right for everyone.
4.3. Where appropriate this information is gathered to ensure support services are available to those tenants who may require them and delivered effectively.
4.4. The sensitive information we collect may include:
4.4.1. Health information;
4.4.2. Information about your gender (we welcome all genders); and
4.4.3. Although we do not specifically request it, we may collect information on your sexuality, political opinions, race, ethnicity and religion (we welcome persons of all backgrounds); and
4.4.4. Criminal, housing, employment and drug, gambling and alcohol use history.
4.5. Under the Privacy Act you have additional rights in relation to sensitive information. If we collect your sensitive information, we will only keep it whilst you consent to us doing so, or if we are required to by law or to protect a legal right. If you want us to delete your sensitive information you may request we do so in writing.
5. What happens if you want to deal with us anonymously or using a pseudonym?
5.1. When contacting us, you can do so either anonymously or by using a pseudonym. If you do so, we may not be able to provide you with accurate or useful information, and you may not be able to access a full range of our services. Further, we may not be able to investigate incidents or complaints you have made.
5.2. We may not be able to provide a tenancy to someone under a pseudonym or anonymously. However we are committed to our obligations under the Privacy Act and welcome you to contact us, on an anonymous basis, to discuss how we can help protect your identity whilst seeking or using our services.
6. How do we collect your personal information?
6.1. We collect personal information directly from you, for example when you provide that information to us, we contact you or when you contact us. We also collect personal information when providing you with our services, you participate in our services, including marketing activities or from publicly available sources such as the internet and social media. Finally we may collect personal information from others, for instance your Nominated Referees.
7. Who do we disclose your personal information to?
Iris respects the confidentiality of your personal information, however it may be necessary for us to at times disclose it to others. Particularly when we are concerned about yours and/or the welfare of others.
7.1. We may disclose your personal information to:
7.1.1. the landowner (landlord) of any property you may reside as a tenant or as a potential tenant of;
7.1.2. entities we work with, associated organisations, business partners or affiliates, in order to provide services to you;
7.1.3. third parties who provide products or services to us (including our accountants, auditors, lawyers, IT contractors, and other service providers);
7.1.4. third parties as required or allowed by law;
7.1.5. during the application process to your Nominated Referees; and
7.1.6. to your social worker or medical health professional (if applicable);
8. How do we hold and secure your personal information?
8.1. We store your personal information digitally and in certain instances in hard copy. All digital material is secured using password protected computers and databases. Any digital transfer of Personal Information is via secure channels such as HTTPS where possible and user passwords are encrypted using a one-way hash. Any database we manage is appropriately secured behind firewalls.
8.2. Some of your data may potentially be stored overseas, most likely the United States due to the use of third party services from businesses that originate in those countries, for instance cloud storage or our email exchange. Where appropriate, Iris has agreements with its storage providers to keep all personal information they store secure, using reasonable and appropriate security methods.
9. Do we send your personal information overseas?
9.1. Iris is an organisation based in South Australia, Australia. However our data may be stored in cloud back up software (such as Office 365, Dropbox, Google Cloud Platform) which may be potentially be stored overseas, most likely in the United States.
9.2. We may upload images and / or footage to the Site or social media accounts from time to time. The Website and social media accounts may be hosted on an overseas server. Where applicable, in the event that your information is sent overseas, we will use our best endeavours to ensure that any overseas service provider will keep all personal information secure and confidential.
10.1. We may use your personal information to communicate directly with you to promote our services. We use direct marketing to provide you with information about our services. If you receive direct marketing material from us, and do not wish to continue receiving it, please contact us by any of the methods stated in this Policy, asking to be removed from all future direct marketing programs. Once we have received your opt-out request, we will remove you from our direct marketing programs as soon as reasonably practicable. Please be aware that unsubscribing from one part of our services will not automatically remove you from all other services.
10.2. We note that the preceding provision is with regard to marketing, we are required to communicate to tenants about their lease (including the provision of maintenance and upkeep services), which may not be opted out from, however we are always willing to discuss how we communicate to you and what method may suit you.
11. How do you access or correct personal information we hold about you?
11.1. You may request access to the personal information that we hold about you by contacting us. Upon receiving an access request we may request further details from you to verify your identity.
11.2. We reserve the right not to provide you with access to your personal information if we are unable to verify your identity to our reasonable satisfaction. An administrative fee may be charged to cover our costs in providing you with access. We will notify you of the administrative fee before it has been incurred. We will respond to your access request within a reasonable period of time by either providing you with access, or if we refuse your access request, we will provide you with reasons. Generally, access requests may be denied where: we believe your request is frivolous or vexatious, we are entitled to reject a request by law, we are unable to verify your identity; or you have not paid the administrative fee (if any).
11.3. If you believe that your personal information held with us is inaccurate or otherwise requires correction, you may send us a correction request by contacting us. We will review your request and respond to the request within a reasonable period of time.
12.1. As a requirement for providing our tenants with the CentrePay service we are to comply with Part 5 Division 3 of the Social Security Administration Act 1999 (Social Security Act) with respect to confidentiality of Protected Information.
12.2. Centrelink may formally request certain information from us which we are required to provide at law and by doing so will not be in breach of our obligations under the Privacy Act.
13. What about the General Data Protection Regulation?
13.1. The GDPR is the European Union (EU) data protection law. Australian-based organisations that offer goods or services to persons in the EU or who may access their website. This provision will not apply to the vast majority of persons who use our site or services.
13.2. We are an Australian based organisation providing services within Australia. From time to time, we may capture or collect personal information that passes through the EU. This might occur, for example, if a person in the EU accesses the Site and we collect analytical data about them, enquiries about our services from the EU, or if one of our customers gives us information about a person in the EU. If this occurs, we will treat the personal information received in accordance with this policy.
13.3. Where data is processed or monitored in the EU, you may have additional rights, such as:
13.3.1. The right to request that we delete your personal information (unless we require that information to comply with a legal obligation, or need it to bring or defend a legal claim); and
13.3.2. The right to restrict our processing of your personal information (where it is inaccurate, would be unlawful to process, or where it has not been deleted due to us needing it to meet a legal obligation).
14. What to do if you have a complaint?
If you have a question or complaint, you can contact us:
Email: [email protected]
Phone: 08 7099 2273
We take all complaints seriously and will respond to you within a reasonable period of time, usually 30 days, unless we consider your complaint to be frivolous or vexatious or if we are unable to verify your identity. If you are not satisfied with the way we have handled your complaint, you can make a complaint to the Office of the Australian Information Commissioner at http://oaic.gov.au.