Data Protection Policy

1. Purpose

WorkingHomes is committed to protecting the personal information of our clients, their crews, accommodation providers, suppliers and staff. This policy sets out how we collect, use, store and protect that information in line with the Privacy Act 1988 (Cth), the Australian Privacy Principles and the Notifiable Data Breaches scheme. [Confirm with your adviser whether the Privacy Act applies to WorkingHomes or is being adopted voluntarily — some small businesses are exempt.]

2. Scope

This policy covers all personal information we handle in our role as an accommodation broker, in any format. It applies to our employees and contractors, and to any third party that handles personal information on our behalf.

3. Our data protection principles

• Open and transparent — we explain what we collect and why, in plain language.
• Collect only what we need — no more information than the task requires.
• Use it for the right purpose — only for the reason it was collected, or a closely related one people would expect.
• Keep it accurate — we take reasonable steps to keep records up to date.
• Keep it secure — protected against misuse, loss and unauthorised access.
• Keep it only as long as needed — then securely delete or de-identify it.
• Respect people's rights — we respond promptly to access and correction requests.

4. Information we handle

• Clients — contact details, company and billing information, project and booking details.
• Crew members — names and contact details provided by their employer for stays.
• Accommodation providers — contact, property and payment details (see our Hosts Privacy Policy).
• Suppliers — business contact and payment details.
• Staff and applicants — information needed for recruitment and employment.

5. Sharing information

We share personal information only with:

• accommodation providers, to the extent needed to fulfil a booking;
• service providers who help run our business (for example hosting, email, accounting and payments), under written confidentiality and data protection terms; and
• regulators or law enforcement, where required or authorised by law.

6. Security measures

• access limited to the people who need it, with multi-factor authentication on business systems;
• encryption in transit, and at rest where our systems support it;
• bank and payment details stored only in our accounting and payment systems;
• secure disposal of paper and electronic records;
• privacy and security awareness for everyone on our team; and
• regular reviews of our systems, suppliers and access permissions.

7. Data breaches

If we suspect personal information has been lost or accessed without authorisation, we will:

1. act immediately to contain the breach;
2. assess the risk of serious harm to the people affected, aiming to complete that assessment within 30 days;
3. notify affected individuals and the OAIC where the breach is likely to result in serious harm; and
4. record what happened and improve our controls to prevent it happening again.

8. Retention and disposal

We keep personal information only as long as we need it or the law requires. Financial and business records are kept for at least 7 years; enquiries that do not proceed are deleted after [24 months]. When information is no longer needed, we securely delete or de-identify it.

9. Individual rights

Anyone can ask to access or correct the personal information we hold about them, ask us to delete information we no longer need, opt out of marketing, or make a complaint. We respond within 30 days. Complaints we cannot resolve can be taken to the Office of the Australian Information Commissioner at oaic.gov.au.

10. Responsibilities and review

Our Privacy Officer oversees this policy and handles requests and complaints. Everyone who works with us is responsible for following it. We review this policy every year, and sooner if the law or our business changes.

11. Contact

Privacy Officer, WorkingHomes Pty Ltd
Email: workinghomes@gmail.com
Phone: +61 8 7092 5945
Postal address: 42 Hereford Street, Glebe NSW 2037

Approved by

Pierce Duffy

Position

Director, WorkingHomes Pty Ltd

Date

22 October 2026