Dubai RERA Ethics & Professional Conduct question: spreadsheet of Downtown Dubai owners phone numbers from a former developer employee

Dubai RERAEthics & Professional Conduct

Sara buys a spreadsheet of Downtown Dubai owners' phone numbers from a former developer employee and calls the owners to ask whether they want to sell. What is her position under RERA Circular 02-2026?

A Only buying the data is a breach; calling owners to ask whether they will sell is still allowed
B Only the calls are a breach; owner data may be bought from any source that offers it
C She breaches the Circular twice: by obtaining owner data unlawfully and by cold-calling owners
D There is no breach so long as she stops calling any owner who tells her to stop

Show the answer and explanation

Answer: C. She breaches the Circular twice: by obtaining owner data unlawfully and by cold-calling owners

RERA Circular 02-2026 strictly prohibits brokerage offices from obtaining owners' or investors' data from any source by unlawful means, and separately prohibits contacting them directly by phone or other channels to offer, market or buy properties. Sara did both: the data came from an insider without the owners' consent, and she called owners she had no documented prior dealings with. Stopping when asked is not a defence, because the contact itself is prohibited. Source: RERA Circular 02-2026, 'Regulations Governing Communication with Property Owners and the Prohibition of Cold Callings' (in force 12 Oct 2026).

Common mistake

Thinking the ban covers only the calls, or only the data, when the Circular targets both acts.

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