How to Run a Privacy Health Check

One data breach can cost your agency thousands or even destroy client trust overnight. A Privacy Health Check gives you a clear picture of how your business handles sensitive client data and highlights weak spots before they become expensive problems. For real estate agencies, property managers, and any business handling personal information, this check is not optional - it’s essential.

What Is a Privacy Health Check?

A Privacy Health Check is a structured review of your business’s privacy practices, policies, and systems. It identifies gaps, ensures compliance with privacy laws like the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), and protects your clients’ personal information. 

Why It Matters 

• Prevent Data Breaches: Catch vulnerabilities before hackers exploit them. 

• Protect Your Reputation: Clients expect their data to be safe; failing that trust can be costly. 

• Stay Compliant: Avoid fines, penalties, and legal disputes. 

• Future-Proof Your Business: Privacy systems that are solid today can handle growth tomorrow. 

Step 1: Review Your Data Collection Practices

Start by looking at what personal information your business collects: 

• Client names, addresses, and contact details 

• Financial or payment information 

• Employment, property, or business records 

• Sensitive information (health, family, financial status) 

Ask yourself: Do you collect only what’s necessary? Are clients aware of what you collect and why? 

Step 2: Check Your Privacy Policy

Your privacy policy should clearly outline: 

• What information you collect 

• How you use it 

• Who you share it with, including any overseas disclosures 

• How clients can access or correct their data 

An outdated or unclear privacy policy increases risk and undermines trust. Transparency is your first defense. 

Step 3: Audit Your Security Measures

Evaluate your current security practices: 

• Are passwords strong and updated regularly? 

• Is sensitive data encrypted both in transit and at rest? 

• Are access controls in place to limit who can view client information? 

• Do you have backups and disaster recovery plans? 

Remember: security isn’t just technology — it’s policies, training, and accountability. 

Step 4: Review Third-Party Vendors

Many businesses rely on external providers for data management: 

• CRM software, cloud storage, or accounting systems 

• Marketing automation platforms 

• Outsourced admin or IT support 

Ensure these vendors comply with privacy laws and maintain strong contractual safeguards, especially if data is stored overseas. 

Step 5: Test Your Response Plan

Even the best protections can’t guarantee 100% safety. Your Privacy Health Check should include reviewing your Data Breach Response Plan: 

• Can you detect and report breaches quickly? 

• Who handles internal communication? 

• How fast can affected individuals be notified? 

• Are employees trained to respond effectively? 

Preparation is key to limiting damage and staying compliant. 

Step 6: Document and Act

Finally, record your findings: 

• Identify gaps and prioritize fixes 

• Update policies, procedures, and training materials 

• Schedule regular privacy audits (annually or biannually) 

Treat privacy like any other critical business asset — ongoing care prevents costly surprises. 

Case Study 1: The Hidden Data Leak No One Noticed

Scenario: A mid-sized property management agency noticed unusual customer complaints, tenants were receiving unsolicited calls referencing information only the agency held. Nothing looked hacked, and all systems appeared normal. But something felt off. 

Solution: The agency conducted a Privacy Health Check and discovered that an old staff member still had active login access to the CRM, and their credentials had been compromised. Access was revoked, passwords were reset, and multi-factor authentication was implemented across all systems. They also updated their offboarding processes and refreshed staff training on data handling. 

Outcome: 

• The unauthorized access was stopped immediately. 

• Client data exposure was contained before further misuse occurred. 

• The agency strengthened its internal privacy procedures. 

• Staff became more aware of how easily silent leaks can occur. 

Lesson: Most privacy issues don’t start with a dramatic hack, they start with small access oversights. Regular access reviews and proper offboarding protect your data more than you think. 

Case Study 2: The Website Form That Exposed Private Information

Scenario: A boutique real estate agency launched a new website with an online enquiry form. Weeks later, a client called saying their private documents (uploaded through the form) were publicly accessible through a direct link. The team had no idea the form was storing uploads in an unsecured folder. 

Solution: A privacy check revealed the web developer hadn’t enabled secure storage settings. The agency immediately removed public access, migrated files to an encrypted system, updated their website privacy notice, and notified affected clients. They also implemented new privacy compliance requirements for all external tech providers. 

Outcome: 

• Sensitive documents were secured before search engines indexed them. 

• Affected clients appreciated the upfront and honest communication. 

• Vendor management and compliance standards were improved. 

• Future website changes now undergo a privacy review first. 

Lesson: Even simple tools like website forms can create major privacy risks. Tech providers must understand privacy requirements and agencies must verify, not assume. 

Key Takeaways

• Cyberattacks can happen anytime – even small agencies are at risk. 

• A Privacy Health Check identifies vulnerabilities before they become costly problems. 

• Review data collection, policies, and security measures regularly to stay compliant. 

• Assess third-party vendors and overseas data handling to reduce risk exposure. 

• Have a tested Data Breach Response Plan so your agency can act quickly if an incident occurs. 

• Document findings and implement fixes to protect client data and safeguard your reputation. 

• Ongoing privacy management is essential for long-term business trust and sustainability. 

Next Steps

Protecting your clients’ privacy and your agency’s reputation starts with understanding your current practices. With O*NO Legal’s Privacy Prepared Health Check, you’ll receive a one-on-one audit, a detailed action plan, and guidance on implementing it through either our done-for-you packages or guided DIY solutions.

Book your free 10-minute call today to identify gaps, strengthen your compliance framework, and ensure your agency is fully prepared to protect both your clients and your business.

Frequently Asked Questions (FAQ)

• How often should a business run a Privacy Health Check?

  At least once a year, or more often if your agency handles large amounts of personal data or has high staff turnover. Regular checks keep your policies, systems, and security measures up to date.

• Who should conduct the Privacy Health Check?

  Your team can review daily data handling, but a privacy lawyer ensures compliance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). Combining both gives a full picture of risks.

• What are the most common problems found during a Privacy Health Check?

  Common issues include weak passwords, outdated policies, old staff logins still active, and unsecured website forms. Most breaches start with small oversights, not major hacks.

• What happens after the Privacy Health Check?

  You’ll receive a clear, step-by-step Action Plan showing gaps, risks, and recommended fixes. You can implement it yourself with guidance or use O*NO Legal’s done-for-you packages. Book your free 10-minute call today to get started and ensure your agency is fully Privacy Prepared.

Luke Shumack – Partner, O*NO Legal

Luke Shumack is one of the Partners at O*NO Legal with a Bachelor of Laws and a sharp focus on helping agencies and business owners stay compliant while scaling with confidence. Since starting his legal career in 2021, Luke has worked closely with real estate agencies, startups, and established businesses on privacy compliance, employment law, contractor agreements, mergers and acquisitions, and corporate governance. Known for his tech-savvy approach and love of efficiency, Luke blends legal precision with practical business strategy—making the complex simple for clients who want to move fast without risk.

Boring legal stuff: This article is general information only and cannot be regarded as legal, financial or accounting advice as it does not take into account your personal circumstances. For tailored advice, please contact us. PS - congratulations if you have read this far, you must love legal disclaimers or are a sucker for punishment.