Real estate agents are explained below but generally yes if over 3m t/o or if they have a tenant database that is covered by the act.
So far I cannot find any published cases that have anything to with strata however so you may be right.
https://www.oaic.gov.au/privacy-law/determinations/
I would still persue this if i was the OP. If OAIC cant help they will advise accordingly anyway so worth the enquiry.
Im looking into this myself as our SM sent out a lot owners bank account details to the committee without their concent in an email claiming she cannot give out owners private details, it was maliciously done.