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).
The OAIC Determination is linked here: https://www.oaic.gov.au/news/media-centre/renttech-platforms-must-stop-unfair-and-excessive-personal-information-collection,-says-privacy-commissioner
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 continuously 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.
We have undertaking a comprehensive review of our application forms to ensure they align with the principles of data minimisation, timing and choice architecture — collecting only what is necessary to establish an applicant’s identity, ability to pay, and suitability for the property.
April 2026 - Data Minimisation
Snug removed several non-essential fields from, or did not collect, the standard application flow to reduce an agency’s data collection footprint. These include, but are not limited to:
- Student status
- Retirement status
- Details of children (name/ages)
- Bankruptcy in Background Check Reports
- Property ownership status
- 100-point ID
We advised at this time to:
- Turn OFF the setting "100 point ID check", 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"
July / August 2026 - Update
We have implemented further rental application data reductions and platform enhancements to give your agency additional control over configurations and flexibility of staged information collection related to your function and activities.
Data field management and collection practices changes are generally summarised as:
Client Setting (default OFF) · Initial Application.
Collected at initial application only when the Snug Client explicitly enables their team-admin setting (default off) eg. Student status.
Client Setting (existing settings with guidance) · Initial Application.
Remain configurable via existing agency settings; new UI guidance (alerts + help-centre links) warns clients about "OAIC sensitive" fields with over-collection risk. eg. ID documents, proof of income, employment details.
Client Setting (default OFF) · Approved Application (staged collection). C
Collected once the application reaches the Approved stage, via SMS/Email requesting Staged Collection information. First release 1: manual "Request Info"; Second Release 2: automated with Approved Application stage workflow eg. Emergency contact, Vehicle details etc.
Platform-wide Removal (no longer collected).
Removed platform-wide (or never previously collected) eg. Gender, Child names & ages, Bankruptcy status, Previous living history, Other property ownership, Concurrent applications, Smoker status, Bond history & claims.
Limited Exceptions (Snug Admin enabled on request).
Snug Support can enable a removed field where a client demonstrates it is necessary to directly facilitate its primary function or activities (e.g. student status for specialised student housing; gender for a women-focused affordable-housing program), or bond / rent assistance for affordable & community housing providers.
Action Recommended for Agencies
- Turn on the OAIC data field management and Staged Application collection in your Team Admin settings for Applications. Irrespective, Snug will turn on this feature for all agencies at the end of August for those that have not voluntarily done so
- Review your Application Settings - ensure your requested fields align with the OAIC Determination, and if varied relate to your specific agency function and activities and the latest regulatory guidance or Prescribed Application Form where relevant
- Train your team including those within your agency and any remote or outsourced application processing support personnel, about these changes and to cease soft collection of information via conversation notes or workaround requests
- Educate your owners and ensure that they aware that certain information is no longer collected and industry practices are changing
Industry Practices Are Changing
We are proud to lead the industry toward a more transparent, fair, data safe and compliant rental ecosystem, with streamlined workflows and efficiencies that enable you to find and select a suitable tenant for your clients.
Feedback
As this space evolves, we welcome your feedback or suggestions on the interpretation and implementation of the recent OAIC determination, Prescribed Application Forms and/or practical experiences we can incorporate in consultations with the government or platform changes. Send us your comments here: https://help.snug.com/hc/en-us/requests/new
Thank you for your support and collaboration on the journey to better renting.
This article was first published in April and updated in August, the content is for general information purposes and not exhaustive, therefore it does not provide any legal advice.