As your partner in rental technology, Snug is committed to providing a platform that not only streamlines your workflow but also upholds the highest standards of regulatory compliance.
Following the recent OAIC determination regarding IRE Pty Ltd (2Apply) released in April 2026, we would like to provide an update on how Snug is responding to these findings and our ongoing commitment to industry best practices.
Understanding the OAIC Determination
The Privacy Commissioner’s investigation into the 2Apply platform found that certain data collection practices were inconsistent with the Australian Privacy Principles (APPs). Broadly, the Commissioner determined regarding:
- Excessive Data Collection: Collecting information such as gender, student/retirement status, bankruptcy history, and dependents' names/ages was deemed not "reasonably necessary" for assessing a tenancy.
- Timing of Collection: Furthermore, upfront collection of all applicant information was not reasonably necessary, e.g., next of kin, vehicle registration was required for successful applicants
- Choice Architecture: The design of application forms must not unfairly pressure applicants into providing more data than required through "bundled consent" or restrictive workflows.
While this ruling was specific to one provider, the OAIC has been clear: all RentTech providers and real estate agencies are expected to align with these findings.
Snug’s Commitment to Compliance
At Snug, we take privacy and compliance very seriously. We are actively reviewing our platform and practices in a rapidly evolving and dynamic landscape of Federal and State reforms, including Prescribed Application Forms. We recognise that with our configurable tools, while agencies remain responsible for the information they collect and store, we can assist in reducing your compliance risk. Therefore, we are currently undertaking a comprehensive review of our application forms to ensure they align with the principles of data minimisation and choice architecture — collecting only what is necessary to establish an applicant’s identity, ability to pay, and suitability for the property.
Immediate Changes: Data Minimisation
During the month, we will progressively remove several non-essential fields from our standard application flow to reduce your agency’s data footprint. These include, but are not limited to:
- Student and retirement status
- Details of children (replaced by total occupant count)
- Bankruptcy in Background Check Reports
- Property ownership status
- 100-point ID
The Road Ahead: Next 60 Days
Over the next 60 days, we will implement further enhancements to give your agency additional configurations and flexibility of staged information collection.
Action Recommended for Agencies
We encourage you to review your Application Settings to ensure your requested fields align with your specific agency function and activities and the latest regulatory guidance, eg
- Turn OFF the setting "100 point ID check" and consider alternatives, e.g., Primary or Sighted ID
- Turn OFF the setting "Require Student letter of offer or ID card"
- Turn Off the setting "Enhanced Disclosures"
Industry Practices Are Changing
We are proud to lead the industry toward a more transparent, fair, and compliant rental ecosystem, with streamlined workflows and efficiencies that enable you to find and select a suitable tenant for your clients.
We welcome your feedback or suggestions, Prescribed Application Forms and/or the recent OAIC determination, which we can incorporate in consultations with the government or platform changes. Survey link: https://snugco.zendesk.com/knowledge/arrange/sections/14224160727951?brand_id=5028348
Thank you for your support and collaboration on the journey to better renting. We will send further communication to keep you updated.