Privacy Policy

This Privacy Policy explains how State Owners Corp trading as SOCM (ACN 160 641 145) (“SOCM”, “we”, “us” or “our”) handles the personal information of the people we deal with in the course of providing owners corporation management services in Victoria.

In this Policy, “personal information” has the meaning given to it in the Privacy Act 1988 (Cth) and the Australian Privacy Principles, and broadly means information or an opinion about an identified individual, or an individual who is reasonably identifiable. Depending on our dealings with you, this may include your name, residential and postal address, date of birth, telephone numbers, email address, lot and unit entitlement details, property ownership and tenancy details, levy and account information, banking and payment details, insurance details, correspondence with us, and records we hold on behalf of an owners corporation. In limited circumstances it may also include “sensitive information” as defined in the Privacy Act. We do not generally collect sensitive information, and where we do, we collect it only with your consent or as otherwise permitted by law.

  1. Collection and storage of personal information

From whom do we collect personal information?

Wherever it is practicable to do so, we collect personal information directly from the individual concerned, and with that individual’s consent. In some cases we collect personal information from other sources, for example:

  • directly from you, in person, by telephone, by email or correspondence, or through our website and online portals;
  • from the records and registers we maintain on behalf of an owners corporation we manage;
  • from solicitors, conveyancers and settlement agents;
  • from your managing agent or property manager, where applicable;
  • from insurers, brokers, valuers and contractors engaged in respect of the common property;
  • from the previous owners corporation manager when we are appointed; and
  • from publicly available records, including the Land Use Victoria title register.

For what purposes do we collect personal information?

We collect personal information so that we can carry on our business and, in particular, perform our role in providing management services to you and your owners corporation in accordance with our management agreement and the Owners Corporations Act 2006 (Vic). Personal information may be collected when:

  • we establish and maintain the owners corporation register and roll;
  • we issue notices of meetings, distribute agendas, ballots and minutes, and administer voting;
  • we raise, issue and collect levies and other amounts owing to the owners corporation;
  • we arrange maintenance, repairs, essential safety measures and other works to the common property;
  • we administer insurance, claims and certificates relating to the owners corporation;
  • you make an enquiry or request that requires us to respond to you;
  • you pay for goods or services, including by credit card or electronic transfer; and
  • we assess applications for employment, including a candidate’s contact details, work history and qualifications.
  1. Anonymity and pseudonymity

Where it is lawful and practicable, you may deal with us anonymously or by using a pseudonym. However, the nature of the services we provide means that this is often not possible or practical. If you choose not to provide the personal information we request, we may be unable to provide our services to you, or to provide them to the same standard.

  1. How we use personal information

We use the personal information we collect for the purpose for which it was provided or collected, and for related purposes that you would reasonably expect, including to:

  • carry out the management services described in section 1 of this Policy;
  • manage the affairs of your owners corporation and respond to your enquiries;
  • perform and confirm authorised financial transactions, including levy collection and payments;
  • communicate with you about your owners corporation and about our services;
  • receive and address feedback, disputes and complaints;
  • meet our regulatory and legal obligations and protect our legal interests; and
  • where permitted under the Australian Privacy Principles, provide you with information about our services.

We use personal information for direct marketing only where doing so is consistent with the Privacy Act and the Australian Privacy Principles. If you do not wish to receive marketing communications from us, you may opt out at any time by using the unsubscribe facility in any electronic message we send, or by contacting us using the details in section 7.

  1. Disclosure of personal information

We may disclose your personal information to third parties for the purposes set out in this Policy, including to enable us to manage an owners corporation. Recipients may include:

  • contractors, tradespeople and service providers engaged in relation to the common property;
  • insurers, insurance brokers, valuers, loss adjusters and assessors;
  • solicitors, debt collectors and other professional advisers;
  • organisations that carry out credit, fraud or other security checks; and
  • third-party software and IT providers that store or process information on our behalf.

We may also disclose personal information:

  • where you have given your express or implied consent;
  • to a prospective purchaser of a lot, or their representative, who requires an owners corporation certificate;
  • to a person entitled to inspect the owners corporation register;
  • where required or authorised under the Owners Corporations Act 2006 (Vic) or any other law; and
  • where we are under a legal duty to do so, or to enforce our agreements or protect the rights, property or safety of any person.

We limit the information we provide to third parties to what they reasonably need for the relevant purpose, and we take reasonable steps to ensure they handle personal information consistently with the Australian Privacy Principles.

  1. Storage and overseas disclosure

We store personal information in secure electronic and physical records, and we take reasonable steps to keep it within Australia. Some of our third-party software and cloud service providers may store or process data on servers located outside Australia. Where this occurs, we take reasonable steps to ensure those providers handle personal information in a manner consistent with the Australian Privacy Principles.

Note for SOCM: confirm whether any of your service providers (for example cloud hosting, accounting or administrative support) store or access data overseas, and list the relevant countries here. If none do, this section can simply state that we do not disclose personal information to recipients located outside Australia.

  1. Security of personal information

We take reasonable steps to protect the personal information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure. These steps include password-protected and access-controlled systems, restricting access to personal information to those who need it to perform their duties, and regularly reviewing our security practices. When personal information is no longer required, we securely archive or destroy it, except where we are required to retain records of the owners corporation or our business.

  1. Access, correction and complaints

You can ask us to access the personal information we hold about you, and to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. Please help us locate the information by giving us enough detail about it. We will respond within a reasonable time. In some circumstances we may decline a request for access or correction, for example where the law permits or requires us to do so, or where granting access would unreasonably affect the privacy of others; if we do, we will explain why.

If you have a question or concern about how we handle your personal information, or wish to make a complaint, please contact our Privacy Officer:

Privacy Officer, State Owners Corp trading as SOCM

Email: [insert privacy contact email]

Post: [insert postal address]

We will acknowledge your complaint, investigate it and respond to you within a reasonable time. If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (www.oaic.gov.au).

  1. Changes to this Policy

We may update this Policy from time to time. The current version will be made available on request and, where applicable, published on our website. We encourage you to review it periodically.

Last updated: [Month Year]

State Owners Corp trading as SOCM