Privacy Policy

Otto Migration Services Pty Ltd

Last updated: May 2025

Otto Migration Services Pty Ltd (ABN 83 644 319 504) ("we", "us", "our") is committed to protecting your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you interact with our website (ottomigration.com) and our migration and education services.

 

By using our website or engaging our services, you acknowledge that you have read and understood this Privacy Policy.

 

1. About Us

Otto Migration Services Pty Ltd is a registered migration agent services business based in Australia. We provide migration advice, visa application assistance, and education services to individuals and families.

 

Contact: info@ottomigration.com | ottomigration.com

 

2. What Personal Information We Collect

2.1 Identity and Contact Information

•       Full name and date of birth

•       Residential and postal address

•       Email address and phone number

•       Passport and visa details

•       Nationality and country of birth

 

2.2 Migration and Legal Information

•       Visa history and immigration status

•       Occupation and skills assessment details

•       English language test results

•       Character and health information as required by the Department of Home Affairs

 

2.3 Financial Information

•       Payment details (processed securely via third-party payment providers)

•       Invoices and transaction records

 

2.4 Website Usage Data

•       IP address and browser type

•       Pages visited and time spent on site

•       Referral source and device information

•       Cookies and similar tracking technologies (see Section 9)

 

2.5 Marketing and Communications Preferences

•       Your consent records for receiving marketing communications

•       Unsubscribe requests and opt-out records

 

3. How We Collect Personal Information

We collect personal information in the following ways:

•       Directly from you when you complete enquiry or booking forms on our website

•       When you contact us by email, phone, or through our online chat

•       When you engage our migration or education services

•       From third parties such as the Department of Home Affairs, skills assessing bodies, or referral partners (only with your knowledge or consent where required)

•       Automatically via cookies and analytics tools when you visit our website

•       Where you have provided written consent, through AI tools used to assist in processing information for service delivery purposes (see Section 12)

 

We will not collect personal information from you without your knowledge or in a deceptive or unfair manner.

 

4. Why We Collect and Use Your Personal Information

4.1 Service Delivery

•       Assessing your visa eligibility and preparing visa applications

•       Communicating with the Department of Home Affairs on your behalf

•       Coordinating with education providers and assessing bodies

•       Managing your bookings and appointments

 

4.2 Business Operations

•       Processing payments and maintaining financial records

•       Improving our services and website functionality

•       Complying with legal and regulatory obligations under the Migration Act 1958 (Cth) and the Migration (Migration Agents Code of Conduct) Regulations 2021

•       Responding to enquiries and providing customer support

 

4.3 Marketing Communications

•       Sending you newsletters, updates, and promotional material where you have given your express consent

•       Informing you of services relevant to your migration journey

 

You may withdraw your consent to receive marketing communications at any time. See Section 8 for details.

 

5. Disclosure of Personal Information

We may disclose your personal information to the following third parties:

•       The Department of Home Affairs and other Australian government bodies

•       Skills assessing authorities (e.g. Vetassess, Engineers Australia)

•       English language testing organisations

•       Third-party service providers who assist us with payment processing, website hosting, email delivery, and analytics

•       Professional advisers such as lawyers and accountants

•       AI platforms used to assist in service delivery, where you have provided prior written consent (see Section 12)

 

We will not sell, rent, or trade your personal information to any third party for their own marketing purposes without your explicit consent.

 

Where we engage third-party service providers, we take reasonable steps to ensure they handle your personal information in accordance with the APPs.

 

6. Overseas Disclosure

Some of our third-party service providers may be located outside Australia (for example, cloud hosting and email services). Some AI tools we use may also process data on servers located outside Australia. Where we disclose personal information to overseas recipients, we take reasonable steps to ensure that those recipients comply with privacy standards comparable to the APPs, consistent with Australian Privacy Principle 8 (APP 8), or we obtain your consent before disclosure.

 

7. Security of Your Personal Information

We take reasonable steps to protect the personal information we hold from misuse, interference, loss, and from unauthorised access, modification, or disclosure. Our security measures include:

•       Encrypted data transmission (SSL/TLS)

•       Secure storage and access controls for all client files, in accordance with section 53 of the Code of Conduct (Duty to keep documents securely)

•       Retention of client files for a minimum of 7 years from the date of last action on the file, as required by section 56(5) of the Code of Conduct

•       Regular review of our data handling practices

•       Restricting input of personal data into AI tools to cases where prior written client consent has been obtained, in accordance with our obligations under section 35 of the Code of Conduct (Duty of confidentiality)

 

However, no transmission over the internet is completely secure. You use our website and provide personal information at your own risk.

 

8. Access, Correction, and Complaints

8.1 Your Rights

You have the right to:

•       Request access to the personal information we hold about you

•       Request correction of inaccurate or incomplete information

•       Withdraw consent to marketing communications at any time

•       Request return of your documents within 14 days of a written request, in accordance with section 54 of the Code of Conduct

•       Make a complaint about the way we handle your personal information

 

8.2 How to Contact Us

To exercise any of the above rights, please contact us at: info@ottomigration.com

 

We will respond to your request within a reasonable timeframe (generally within 30 days).

 

8.3 Complaints — Privacy

If you are not satisfied with our response to a privacy complaint, you may contact the Office of the Australian Information Commissioner (OAIC):

•       Website: http://www.oaic.gov.au

•       Phone: 1300 363 992

 

9. Cookies and Website Analytics

Our website uses cookies and similar technologies to improve your experience and to analyse website traffic. Cookies are small files stored on your device. We use:

•       Essential cookies necessary for the website to function

•       Analytics cookies (e.g. Google Analytics) to understand how visitors use our site

•       Marketing cookies to measure the effectiveness of our promotions

 

You may disable cookies through your browser settings. Disabling certain cookies may limit your ability to use some features of our website.

 

10. Retention of Personal Information

We retain your personal information for as long as necessary to provide our services, comply with legal obligations, and resolve any disputes. In accordance with section 56(5) of the Code of Conduct for Registered Migration Agents (Migration (Migration Agents Code of Conduct) Regulations 2021), migration-related client files are retained for a minimum of seven years after the last action on the file.

 

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or regulatory guidance, including updates to OMARA guidance on the use of AI. The updated version will be posted on our website with a revised version number and date. We encourage you to review this policy periodically.

 

12. Use of Artificial Intelligence (AI) Tools

 

12.1 Legal Framework — AI Does Not Alter Our Obligations

Under section 280 of the Migration Act 1958 (Cth), only registered migration agents (RMAs), Australian legal practitioners, and a limited number of exempt persons may lawfully provide immigration assistance in Australia. Immigration assistance is defined under section 276 of the Act and includes activities such as preparing a visa application, advising on visa options, and making representations to government officials.

 

The use of AI tools does not constitute an exemption to these requirements. There are no exemptions to section 280, including information generated through AI. Depending on the circumstances, a person who provides immigration assistance through AI without being registered or otherwise authorised may commit an offence under section 280 of the Act.

 

12.2 Our RMA Remains Fully Responsible — Section 24 COC

Otto Migration Services may use AI tools to assist in the delivery of migration services. However, our registered migration agent (Monica Gasparotto, MARN 2016560) remains fully and personally responsible for all immigration assistance provided to clients, regardless of whether AI tools were used in its preparation.

 

This responsibility is grounded in section 24(1) of the Code of Conduct, which requires a migration agent to take all reasonable steps to ensure the quality, accuracy and timeliness of any work or services performed by another person for the purpose of assisting the agent to give immigration assistance. For the purposes of this policy, AI tools are treated as a work-assistance mechanism and all obligations under section 24 apply accordingly.

 

An RMA who uses AI and provides inadequate or inaccurate information to a client remains responsible for that information, regardless of its source. All AI-generated content is reviewed, verified, and approved by our RMA before being used in any client matter or submitted to the Department of Home Affairs.

 

 

12.3 Confidentiality Obligations — Section 35 COC

Section 35 of the Code of Conduct imposes a strict duty of confidentiality on migration agents. Except as required by law, a migration agent must not disclose, or allow to be disclosed, to a third person any personal information relating to a client or former client, or their affairs, without the client's written consent.

 

For the purposes of this obligation, the input of client personal information into an AI platform is treated as a potential disclosure to a third party. Accordingly:

•       We will not enter your personal information into any AI platform or system without first obtaining your written consent

•       Written consent will be sought as part of our client engagement process, either through our service agreement or a separate consent form

•       You may withdraw consent at any time by notifying us in writing at info@ottomigration.com

•       Withdrawal of consent will not affect the lawfulness of any processing carried out prior to withdrawal

 

12.4 How We Use AI Tools

AI tools may be used internally for the following purposes, always under the direct supervision and final approval of our RMA:

•       Drafting letters of advice, correspondence, and client communications

•       Analysing and summarising legislative and policy documents

•       Supporting research on ANZSCO occupations and occupation lists

•       Preparing draft supporting documents such as position descriptions and genuine position statements

•       Reviewing and formatting documents

•       Analysing meeting summaries and consultation notes

 

In every case, AI-generated output is a draft only. It is reviewed, corrected where necessary, and approved by our RMA before any use in a client matter. No AI output is submitted to the Department of Home Affairs or any government official without prior RMA review, edit and approval.

 

 

12.5 Minimisation of Personal Data in AI Tools

Where you have provided written consent, we take the following steps to minimise privacy risks in connection with AI tool use:

•       Where possible, we anonymise or de-identify your personal information before entering it into AI tools

•       We use only AI platforms that provide adequate data security and privacy protections

•       We do not use AI tools that store, share, or train on your personal data without explicit authorisation

•       Access to AI outputs containing your personal information is restricted to authorised staff only

•       Client files containing AI-generated content are maintained securely in accordance with sections 53 and 56 of the Code of Conduct

 

12.6 Duty to Maintain Skills and Knowledge — Section 22 COC

Section 22 of the Code of Conduct requires a migration agent to maintain sufficient knowledge and skills to give immigration assistance professionally and competently. Our use of AI tools is subject to this obligation — we do not rely on AI as a substitute for professional knowledge and skill, but as an efficiency tool that supplements the RMA's expertise and judgment.

 

Our RMA regularly reviews and validates the accuracy of AI outputs against current legislation, Department of Home Affairs policy, and OMARA guidance, in fulfilment of the duty to maintain skills and knowledge under section 22.

 

12.7 Record Keeping — Section 56 COC

In accordance with section 56 of the Code of Conduct, all client files must include copies of all written communications and documents relevant to the client's matter. Where AI tools have been used to generate documents that form part of a client file, the final reviewed and approved versions of those documents are retained on the client file in accordance with section 56. Client files are maintained for a minimum of seven years after the last action on the file.

 

12.8 Transparency — Informing Clients

If AI tools will be used in the delivery of your immigration assistance, we will explain this to you in advance, as required by OMARA guidance. This ensures compliance with your right to informed consent and with the privacy principles applicable to the use of AI. Details of the AI platforms currently in use are available on request by contacting info@ottomigration.com.

 

12.9 Concerns and Complaints About AI Use

If you have any concerns about the way AI has been used in your matter, please contact us in the first instance at info@ottomigration.com. We will address your concern promptly and in accordance with our obligations under the Code of Conduct.

 

If you believe our use of AI has resulted in a breach of the Code of Conduct, you may lodge a complaint with OMARA at http://www.mara.gov.au. If you believe our use of AI has resulted in a breach of your privacy rights, you may lodge a complaint with the OAIC at http://www.oaic.gov.au.

 

13. Our Commitment to Ethical AI

Otto Migration Services is committed to the responsible and ethical use of AI in accordance with Australia's AI Ethics Principles (Department of Industry, Science and Resources), which include the following core principles as they apply to our practice:

•       Human, social and environmental wellbeing: AI use must benefit our clients and not cause harm

•       Human-centred values: we respect the rights, diversity, and autonomy of all clients

•       Fairness: we do not use AI in ways that discriminate against or disadvantage any client

•       Privacy protection and security: personal information used in AI systems is protected in accordance with the APPs and section 35 of the Code of Conduct

•       Reliability and safety: all AI outputs are verified for accuracy by our RMA before use

•       Transparency and explainability: we inform clients about AI use and obtain written consent before entering personal data into AI systems

•       Contestability: clients may raise concerns about AI use and request human review of any AI-assisted output

•       Accountability: our RMA remains personally accountable for all immigration assistance provided, whether or not AI was used in its preparation