On 14 June 2024, REINZ filed submissions on Privacy Amendment Bill (Bill). The Bill introduces a new information privacy principle, IPP 3A, which applies when personal information is collected indirectly from an individual. This Bill is important for REINZ and our members due to its impact on how we collect and share property and sales data.

Since we are not privacy experts, we kept our submissions high-level and assessed the proposed Bill against our 2022 submissions, when the Ministry of Justice first consulted the public on potential reform options. Compared to the 2022 options, which we were concerned would be excessively burdensome and, in some cases, unworkable for the real estate sector, we believe the Bill has landed well. IPP 3A is loosely based on the privacy requirements for directly collected personal information and includes several practical exceptions for when notification is not required. Before filing our submissions, we sought feedback from Industry Leaders, Sector Groups, Ambassadors, along with sharing an advanced draft of our submissions with the Legal and Compliance Group.

If the Bill becomes law, members will need to prepare for the upcoming changes by updating privacy principles and relevant contracts to ensure individuals are notified at the earliest opportunity about who their information is indirectly shared with and why. We have said to MoJ that we would be keen to engage with them at an early stage on the education side around guidance and educating REINZ members on preparing for the new indirect collection regime. We will continue to monitor the progress of this Amendment Bill and keep you updated on this.