30 Days to Privacy & AML Readiness for Real Estate Agencies
New regulations are accelerating privacy and AML/CTF expectations for real estate agencies. Here’s how a small agency ran a focused 30‑day compliance uplift—mapping personal data, tightening access with MFA, updating policies and retention, and formalising third‑party KYC—to cut breach risk, avoid OAIC pain, and keep deals moving.
1) The Wake‑Up Call: Compliance Deadlines Meet Daily Deals
“We can’t lose a listing because of paperwork,” the principal said. “But we also can’t afford an OAIC notification.” With stricter privacy rules and AML/CTF obligations coming into force—NSW VOI tightened from 1 July 2024, Queensland’s seller disclosure regime starts 1 August 2025, new real estate rules land around 31 March 2026, and broader AML/CTF coverage from 1 July 2026—the agency needed action that fit around appraisals, opens, and settlements.
Mantra: Document your business or get out.
- Risk on the table: weak breach preparedness or third‑party controls triggering OAIC notifications, civil penalties, and operational disruption.
- Goal: a 30‑day uplift that is practical for small teams and remote staff.
2) The 30‑Day Plan: From Intent to Impact
Scope the sprint
- Map personal information and data flows across CRM, email, DMS, e‑sign, ID/VOI apps, PM trust systems, and spreadsheets.
- Restrict access and enable MFA on CRMs and document platforms; enforce least‑privilege roles.
- Update privacy policy and data retention schedule aligned to the Privacy Bill 2024 direction and the Privacy Act (mandatory if turnover > $3M; best practice for all).
- Formalise third‑party KYC reliance with written agreements, SLAs, and monitoring.
- Stand up breach readiness with an incident playbook and tabletop drill.
Single source of truth: one shared tracker (sheet or GRC tool) with owners, due dates, and evidence links—so remote workers can follow instructions step‑by‑step.
3) Challenge: “Where Is Our Client Data, Really?”
Lesson: Inventory before security
The team believed “it’s all in the CRM.” It wasn’t. IDs sat in email, bank details in PDFs, and tenancy references in an assistant’s desktop folder.
How we fixed it
- Data map by lifecycle: enquiry, appraisal, listing, sale/lease, settlement, aftercare.
- Register each data item (e.g., VOI documents, bank details), its system of record, access roles, and retention period.
- Eliminate shadows: move stray files into the DMS; switch email attachments to secure links.
Result: clarity on what personal information we hold and where it flows—foundation for controls and retention.
4) Challenge: VOI/KYC That Stands Up to Audit
Lesson: If you rely on third parties, prove it
With tighter VOI in NSW from 1 July 2024 and wider AML/CTF obligations looming, ad‑hoc checks weren’t enough.
How we fixed it
- Approved providers: shortlist VOI/KYC vendors; conduct basic due diligence (security posture, data location, SOC/ISO claims).
- Written reliance agreements: spell out responsibilities, SLAs, audit rights, and notification timelines for suspected fraud.
- Operational guardrails: mandatory capture of VOI reference numbers in the CRM; no deal progresses without them.
- Monitoring: monthly sample of completed VOI files; log exceptions and corrective actions.
Now KYC steps are consistent, evidence‑based, and pre‑packaged for regulator scrutiny.
5) Challenge: Too Many Keys, Not Enough Locks
Lesson: Least privilege + MFA beats wishful thinking
Agents, PMs, and contractors had broad access “to help each other.” That’s exactly how breaches happen.
How we fixed it
- Role‑based access: defined roles in CRM/DMS; removed dormant accounts; enforced MFA everywhere.
- Remote‑ready runbooks: one‑page “how to” with screenshots so remote workers follow instructions without IT on speed dial.
- Device standards: screen lock, disk encryption, and phishing‑resistant MFA; blocked personal email auto‑forwarding.
Quick win: access reviews each quarter; auto‑revoke on off‑boarding day.
6) Challenge: Policies and Retention That People Actually Use
Lesson: Plain‑English beats shelfware
Privacy policies and retention schedules were outdated and ignored.
How we fixed it
- Policy refresh aligned to the Privacy Bill 2024 momentum and OAIC guidance; added clear contact for privacy queries.
- Retention schedule by record type (IDs, contracts, trust records, marketing lists) with legal bases and secure deletion steps.
- Workflow prompts in CRM to purge expired records and avoid over‑collection.
Outcome: fewer places to breach, less to disclose, and faster responses to access/erasure requests.
7) Challenge: “What If Something Goes Wrong?”
Lesson: Practice the breach before it happens
Weak breach preparedness is what turns a mishap into an OAIC notification and civil penalties.
How we fixed it
- Incident playbook: triage, contain, assess material risk, notify (clients, OAIC, banks) where required, and post‑mortem.
- Tabletop drill with a realistic scenario (lost agent laptop holding VOI PDFs); timed decision points and comms templates.
- Vendor coordination: tested notification pathways with the VOI provider; captured SLA performance.
Result by Day 30: a rehearsed response, filled gaps, and confidence that operations can continue during an incident.
8) From Sprint to System: Keeping It Compliant (and Commercial)
Make it stick
- Single source of truth: one compliance dashboard with status, risks, and evidence links.
- Quarterly reviews for access, vendor reports, and retention deletions.
- Training: 20‑minute refresher for new starters and contractors—“document once, use many times.”
Key dates to track
- NSW: Increased VOI expectations from 1 July 2024.
- Queensland: New seller disclosure regime from 1 August 2025.
- Real estate designated services: new rules from around 31 March 2026.
- AML/CTF expansion: obligations on certain property services from 1 July 2026.
Compliance is now a core business capability. Do the simple things well, document relentlessly, and let your agents focus on winning listings—securely.
