On the harbour
151 Property is a specialist manager of real estate in Australia. It collects, holds, uses and discloses personal information to carry out its activities which include managing real estate in commercial, industrial, retail, residential and development sectors in Australia and New Zealand.
Collection of personal information
The kinds of personal information that 151 Property collects and holds may include (but may not be limited to) your:
- Date of birth
- Contact details (for example, postal address, e-mail address, telephone number(s), facsimile number(s))
- Occupation – company and position
- Bank account details
- government related identifiers (e.g. Tax File Number, passport number or driver licence number)
- IP addresses
- Real estate preferences
- For job applicants, contractors and assessment of key people – education and employment history
151 Property collects personal information directly from you and in the course of our dealings with you, and in particular from correspondence, emails and business cards that you provide to us, from telephone conversations we have with you and through your use of our website. 151 Property also collects personal information from service providers, such as Link Market Services Limited, leasing agents and external legal services providers.
151 Property may also collect personal information about you from publicly available sources of information and, if you consent, from third parties (including ASIC and police checks).
If 151 Property is not able to collect personal information about you we may not be able to provide you with services and assistance to the extent that they require us to collect, use or disclose personal information, or, in the case of job applicants, assess your application for employment.
Use and disclosure of information
1. Use and disclosure of personal information except government related identifiers
151 Property may use or disclose your personal information for the purpose for which it was collected. 151 Property may also use or disclose your personal information for any secondary purpose that is related to a purpose for which we collected it, where an individual would reasonably expect it to be used or disclosed for that purpose.
The purposes for which 151 Property uses and discloses personal information will vary depending on your relationship with us, and may include:
- providing real estate investment management services;
- administrative functions, including monitoring, auditing, evaluation, modelling data, answering queries;
- to communicate with you;
- developing and improving its services and obtaining feedback;
- for job applications, assessing the application for employment with 151 Property;
- for contractors, assessing suitability to provide contracting services to 151 Property and entities and investments managed by 151 Property; or
- for marketing purposes relating to our services.
151 Property will not generally disclose personal information to parties outside 151 Property, other than for a purpose directly related to our activities as a real estate investment group, unless we have your consent to do so.
In order to deliver our services to you, we occasionally need to disclose personal information to our related companies, agents, contractors or third party service providers, such as providers of administrative, telecommunications, information technology/ computer or other services. 151 Property also discloses personal information to service providers such as Link Market Services Limited.
Your personal information may be disclosed to other parties where you have expressly or impliedly consented to the use or disclosure or it is required or authorised under an Australian law or by court/ tribunal orders. For example, 151 Property discloses personal information associated with its regulatory reporting and compliance obligations, to statutory bodies such as the Australian Securities and Investments Commission.
151 Property may share personal information with related organisations in connection with the purposes described in this Policy. Some of the organisations to whom 151 Property might disclose personal information are located outside of Australia. They are generally located in the United States of America, United Kingdom, Hong Kong and Singapore. When 151 Property discloses personal information to an overseas recipient, we take reasonable steps to ensure that the personal information is handled securely and in accordance with this Policy, the Act and the APPs. We also require that these organisations use this information only for the purposes for which we collected the information (or a secondary related purpose as described above) and otherwise follow our reasonable directions with respect to this information.
2. Use and disclosure of government related identifiers
If you have provided a government related identifier to 151 Property (e.g. your Tax File Number, Australian passport number or driver licence number issued by a State or Territory authority), 151 Property will not use or disclose your government related identifier except in accordance with the Act and the APPs. For example, 151 Property may use or disclose your government related identifier if the use or disclosure of the identifier is:
- reasonably necessary for 151 Property to verify your identity for the purposes of 151 Property’s activities or functions;
- reasonably necessary for 151 Property to fulfil its obligations to an agency (as defined in the Act) or a State or Territory authority;
- required or authorised by or under an Australian law or a court/tribunal order; or
- otherwise permitted by APP 9.2.
As mentioned above, 151 Property may send marketing material to its customers, including, where they have opted in, via email or other digital communications. If you no longer wish to receive such promotional information from 151 Property, you should advise the 151 Property Privacy Officer using the contact details in the ‘Contact Us’ section below.
151 Property maintains strict standards and security procedures to prevent misuse, interference and loss, unauthorised access, modification or disclosure. 151 Property will take reasonable steps to ensure that the personal information it collects is accurate and up-to-date.
Personal information received by 151 Property is held electronically on secure information technology systems of 151 Property and may only be accessed by its authorised employees who require access in connection with the purposes described in this Policy. Servers are backed up daily, weekly and monthly and archives are stored in a secure location.
Personal information is also held in hard copy format. These documents are stored in lockable storage cabinets in secure premises.
We use “cookies” to enhance functionality and to keep track of visits to our website.
Access to information
You can request access to personal information that 151 Property holds about you, and you can request that 151 Property corrects that personal information.
Before giving you access to your records, 151 Property will require you to prove your identity. We may ask you to verify your full name and other aspects of personal information.
151 Property will give you access to your personal information, and take reasonable steps to correct it if we consider that it is incorrect, unless there is a law that allows or requires us not to.
If 151 Property refuses to give you access to your personal information, or to correct it, 151 Property will notify you in writing and will provide reasons.
If you would like to access or correct your personal information, contact our Privacy Officer (details are below).
If you wish to make a complaint to 151 Property about how we have collected, handled, used or disclosed your personal information, you should forward a written complaint to our Privacy Officer:
Privacy Officer 151 Property Suite 602, Level 6 151 Castlereagh Street SYDNEY NSW 2000
151 Property will aim to respond in writing within 30 days of receiving a complaint.
If the complaint remains unresolved, you have the option of notifying the Office of the Australian Information Commissioner (OAIC). Contact details can be found at OAIC’s website: www.oaic.gov.au
If you have any questions or would like further information about how 151 Property handles personal information, please contact our Privacy Officer (details are above).
Updates to this Policy
151 Property reserves the right to change this Policy at any time. 151 Property will notify any changes by posting an updated version of the Policy on the website.
Policy last updated: July 2017