Privacy compliance · Melbourne, Australia

The obligation started on 1 July. Most businesses it applies to still don't know.

AML/CTF Tranche 2 made real estate agencies, conveyancers, accountants, solicitors, buyer's agents and property developers reporting entities. With it came something quieter: the Privacy Act small business exemption stopped covering the personal information handled in that work — whatever your turnover.

ComplyHub builds your privacy program in four weeks, for a fixed fee, without a law firm's hourly rate.

No obligation. We'll tell you if you don't need us.

Where the law actually stands

Three dates matter. Only one has already passed.

We sell what is in force. Plenty of people will tell you every small business is about to fall under the Privacy Act — that isn't law yet, and saying otherwise is how you end up buying something you don't need. Here is what is in force, what is scheduled, and what is still only proposed.

Date
What changed
Status
10 Jun 2025
Statutory tort for serious invasions of privacy Individuals can sue directly. Applies regardless of your turnover.
In force
01 Jul 2026
AML/CTF Tranche 2 — new reporting entities Real estate agencies, conveyancers, accountants, solicitors, buyer's agents and developers providing designated services. The Privacy Act now applies to personal information handled in that work, even under the $3m threshold.
In force
10 Dec 2026
Automated decision-making disclosure obligations If software makes or substantially assists a decision about a person, your privacy policy must disclose it. This is the second dated deadline of the year.
Scheduled
Not set
Removal of the $3m small business exemption entirely Government supports it in principle. No Bill passed, no commencement date. Treat any specific date you're quoted as commentary.
Proposed

General information, current as at the date of publication — not legal advice. We review this table monthly and date every change.

Who this applies to

Six professions, one commencement date.

The obligation attaches to the service you provide, not to the size of your business. Find the one that describes you.

Real estate agencies & property managers

Tenancy applications, 100-point checks and every unsuccessful applicant still sitting in the CRM.

Conveyancers & settlement agents

Certified identity documents and settlement files that nobody has decided when to destroy.

Accountants & bookkeepers

Tax file numbers, bank feeds, payroll and director identity documents — mostly moving by email.

Solicitors & small law firms

You can read the legislation. The implementation is the project nobody has time for.

Buyer's agents & developers

Small teams, full borrowing capacity on file, and the same obligations as a national franchise.

Finance & mortgage brokers

A long disclosure chain, and December's automated decision-making rules land right on your software.

What we do

Four ways to work with us.

Start small if you want to see how we work. Start with the foundations if you already know where this is heading.

Privacy health check

$750 + GST, one-off

A half day of our time and a written answer to one question: how exposed are you?

  • Review of your current policy, forms and file handling
  • Written findings memo against the Australian Privacy Principles
  • Prioritised list of what to fix first
  • Credited in full against foundations if you proceed within 60 days

Privacy foundations

$4,500 – $7,500 + GST, one-off

A complete privacy program, built and handed over in four weeks.

  • Data map of every place personal information lives
  • Gap assessment against the 13 Australian Privacy Principles
  • Privacy policy and collection notices written for your practice
  • Notifiable data breach response plan
  • 60-minute staff training session

Most clients choose this

ComplyHub annual

from $10,500 + GST, per year

Foundations plus twelve months of maintenance, bundled.

  • Everything in Privacy foundations
  • Quarterly compliance review
  • Policies and registers updated as the law changes
  • Breach response line — call us first, not your lawyer
  • Annual staff training refresher

Ongoing privacy officer

$400 – $800 + GST, per month

Maintenance only, for businesses whose program is already built.

  • Quarterly reviews and register upkeep
  • Regulatory change monitoring
  • Breach response line
  • If someone else built your program, we'll assess it first ($1,500)

How we work

Three things we'd want to know if we were buying this.

We don't sell the proposal

The blanket removal of the small business exemption is not law and may not be for some time. We'll never quote you a deadline that doesn't exist. Everything we sell is tied to an obligation already in force, and the ledger above is on every page for exactly that reason.

Fixed fee, fixed scope

You get a scope and a number before we start, and the number doesn't move unless you ask for something outside it. No hourly billing, no six-minute units, no invoice for the phone call.

Onshore, and we'll show you

Our work is delivered from Melbourne and your information stays in Australia. We can name every system that touches it — which is the same question we're about to ask you about your own business.

We are not a law firm. We don't provide legal advice, and our engagement letter says so plainly. What we do is implementation: mapping data, writing operational documents, training staff and maintaining registers. Where a question is genuinely one of legal interpretation, we tell you and refer you to someone who can answer it.

Find out where you stand.

Twenty minutes on the phone. We'll walk through what you collect and where it goes, and tell you plainly whether you have a problem. If you don't, we'll say so — that call has happened before and it will happen again.