Whitepaper. Implications of Federal Privacy Reforms for Federal Government Agencies. Date Released: 1 August 2013

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1 Whitepaper Implications of Federal Privacy Reforms for Federal Government Agencies Date Released: 1 August 2013 Authors: Amanda Biggs and Helaine Leggat Disclaimer This White Paper is published for general information purposes only. Nothing in the White Paper is directed at any particular person or government agency. Nor does it address any particular subject matter relating to personal information or privacy law. Nothing in the White Paper is intended as or constitutes legal advice. You, the reader, are entirely responsible for any reliance you make on the information published herein. Please ensure that you obtain appropriate legal advice. Astral Consulting Services Pty Ltd (ABN ) Astral Consulting Services Pty Ltd ( Astral ) owns the copyright in this document (including the layout, format and template). This document may not be reproduced or used without the prior written consent of Astral. Astral Consulting Services Pty Ltd 2013 Commercial in Confidence

2 Implications of Federal Privacy Reforms Version 1 1 August 2013 Page 2 of 6 1. Introduction Federal privacy law reforms which come into effect from 12 March 2014 will impact the services and functions of all federal departments and agencies (agencies i ) which process personal information ii some, more than others. Compliance with the new Privacy Amendment (Enhancing Privacy Protection) Act 2012 is expected from 12 March Agencies must take responsibility for ensuring their business processes comply with the escalating information management and privacy regulations, or risk significant penalties. Through the implementation of common business processes, agencies have the potential to leverage a standard approach to managing personal information. This Whitepaper provides a conceptual overview of information management governance, the impacts of the new Act, and identifies what actions your government agency can take to be ready for the changes. 2. Information Management, Privacy and Security Information Management entails organising, retrieving, acquiring, securing and maintaining (processing) information. It is closely related to and overlapping with the practice of data management and incorporates the processing of personal information. Personal information is information, albeit a particular kind of information iii. Compliance with the Act will not be possible without good information management practices. Furthermore, while information security can exist without privacy, privacy cannot exist without security. Compliance therefore, demands all facets of information management, including information security management. The Act requires agencies to have clearly defined and up-to-date privacy policies and processes in place to ensure compliance. Until now, a recommendation, these requirements will be enforced by the new Privacy Act. 2.1 What is Information Management Governance? Information Management Governance is a sub-set of Corporate Governance it means doing the right thing with respect to managing information. An effective Information Management Governance model will link information management needs with legal requirements, records management and with IT processes to eliminate unnecessary information and ensure that all the information required by federal agencies is available in the right place at the right time to the right people. Whilst data and documents are typically treated differently in practice with different systems and rules to manage them, they need to be managed in concert to comply with legislation. 2.2 Framework for Information Governance An Information Governance Framework should enable a public sector agency to better manage information, including personal information, by providing a framework in which agencies can dispose of unnecessary information promptly, store and retrieve information easily and as required, consistently store and identify public records, and meet regulatory, service and evidence requirements with regard to information.

3 Implications of Federal Privacy Reforms Version 1 1 August 2013 Page 3 of 6 An Information Governance Framework requires administrative, technical and physical controls to address the confidentiality, integrity and availability of internal agency and third party information. These controls are achieved through policy and support mechanisms in the form of documented and consistently monitored and applied procedures, standards, guidelines, baselines that address, by way of example the following: Privacy, information security, records management and legal requirements; Systems that support and streamline end-user management of information needed for daily tasks and official agency records - these should increase the efficiency of record keeping and data retrieval for agency users; and A legal hold and discovery case management system that significantly reduces the business and operational disruption required to meet legal obligations. 2.3 Integrated Information Management Business process integrated information management ensures that whoever has access to the data in systems will only have access to the relevant document(s) associated with each specific step of a business process. The challenge in managing business process integrated information is controlling access to the information, data governance iv and maintaining the security and privacy of data and related documents for the entire lifecycle v of the information, during the business process execution and thereafter, for audit and archival purposes. 3. New Privacy Act All government agencies (and private sector organisations with annual revenues greater than $3 million) are required to comply with the 13 Australian Privacy Principles (APPs) in the Act. The APPs are principles which regulate how personal and sensitive personal vi information is managed throughout its lifecycle. Personal information is information that identifies you or could reasonably identify you. Sensitive information is a subset of personal information and includes information such as, for example, health information. The Act introduces changes to credit reporting laws including more comprehensive credit reporting requirements, which could impact some government agencies. These changes aim to ensure that credit risk can be adequately assessed whilst ensuring the protection of personal information. 3.1 Impact on Government Agencies* The new APPs replace the current Information Privacy Principles for Australian government agencies. The following represents a summary of the changes and the new obligations that will be introduced by the new APPs specific to how agencies manage personal information: No. Description of Change/New Obligation Impacting Agencies 1. Must have a clearly expressed and up to date privacy policy which is readily available to relevant parties. Previously this had been a recommended but not enforced requirement. 2. Must take reasonable steps to implement practices, procedures and systems that will ensure compliance with the APPs and any registered APP codes, and enable the agency to deal with inquiries and complaints by individuals.

4 Implications of Federal Privacy Reforms Version 1 1 August 2013 Page 4 of 6 No. Description of Change/New Obligation Impacting Agencies 3. Accommodate new obligations to give individuals the option of not identifying themselves, or of using a pseudonym, when dealing with the agency in relation to a particular matter (some exceptions apply). 4. Comply with changed obligations relating to the collection of personal and sensitive information. 5. Comply with new obligations in relation to the receipt of personal information which is not solicited by the organisation. 6. Adhere to new (more prescriptive) requirements for the use and disclosure of personal information. Different obligations apply to the use or disclosure of sensitive information. 7. Cannot use or disclose personal information for direct marketing purposes except in specified circumstances. 8. Accommodate increased accountability in relation to an agency s disclosures of personal information to overseas recipients. 9. Must adhere to new obligations in relation to the quality of personal information. 10. Take reasonable steps to protect the personal information it holds from interference, in addition to misuse and loss, and unauthorised access, modification and disclosure. 11. Take reasonable actions to destroy or de identify information if the agency no longer needs the information for any authorised purpose (some exceptions apply). 12. Required to respond to requests for access of personal information within 30 days (Exceptions apply Freedom of Information Act 1982 or other legislation). 13. Respond to a request to correct personal information within 30 days. * Source: Implications If There is Non-Compliance The new Privacy Act grants the Australian Privacy Commissioner greater authority to resolve complaints, conduct investigations and to promote privacy compliance. Of significance, the Commissioner will be able to: Conduct Performance Assessments (previously known as audits) of any agency at any time to determine whether they are handling personal information in accordance with the APPs, new credit reporting provisions and other rules and codes; Conduct own motion investigations (OMIs) when agencies are suspected of non-compliance (even without an official complaint) and make enforceable determinations based on the findings; and Direct an agency to provide the Commissioner with a privacy impact assessment and report to the responsible Ministers when an agency fails to comply with the direction.

5 Implications of Federal Privacy Reforms Version 1 1 August 2013 Page 5 of 6 4. How to Prepare for the New Privacy Act Government agencies need to begin immediately to put in place the processes and supporting IT systems to demonstrate their compliance with the new Act. Astral Consulting can assist agencies by conducting a variety of audits and providing a multidisciplinary approach to information privacy compliance. Astral Consulting can assist agencies with information classification and understanding the difference between the obligation to protect and secure information as against their obligation to make information available under the Freedom of Information Act. 4.1 Readiness Audit Astral Consulting can assist agencies by conducting a Privacy Amendment Act 2012 Readiness Audit. This will: Identify the information owned by the agency that is subject to the new Privacy Act; Assess the agency s current privacy policy and supporting procedures; and Provide input to a roadmap defining the actions required in order for the agency to comply with the new Privacy Act by March 2014, which could include: o Development of compliance programs o Development of privacy policies and procedures o Development of information security policies and procedures o Data protection strategies o Training on privacy and security awareness o Checklists, FAQs and guidelines 4.2 Performance Assessment Audit Astral Consulting can assist agencies by conducting a Performance Assessment Audit. This will: Determine whether they are handling personal information in accordance with the APPs; and Make recommendations for how to address any shortfalls in compliance. 5. Astral Contact Details For further information, please contact: Marie Felsbourg (Astral CEO) (ph) , (m) , (e) About the Authors Amanda Biggs is a Principal Consultant at Astral Consulting, and has 19 years experience in information management, working with government agencies and private sector organisations. Amanda has a Bachelor of Business Systems degree and is a certified PROSCI practitioner. Helaine Leggat holds a Bachelor of Law degree, specialises in Information Technology Law, is a Certified Information Systems Security Professional (CISSP), Certified Information System Manager (CISM), Certified Information Privacy Professional, United States (CIPP/US) and Certified Information Privacy Professional, Information Technology (CIPP/IT).

6 Implications of Federal Privacy Reforms Version 1 1 August 2013 Page 6 of 6 About Astral Astral Consulting was founded in 2000 by a talented group of business and technical consultants. Today, Astral has over 25 consultants and is a leader in the Enterprise Content Management (ECM) and Business Process Management (BPM) space. Astral understands that amendments to Australia s privacy regime are complex and onerous. Compliance with the Act demands both knowledge of information privacy law and the ability to interpret its purpose in the form of information management into meaningful operational processes. Astral s consultants are highly regarded for their knowledge, advice and independence. The technical and business skill-set of the Astral team is deemed best of breed' by prominent business partners and clients. Astral Consulting is the trusted strategy partner of many leading corporations, across a wide range of industries in the Asia Pacific region. Astral has offices in Melbourne and Sydney. i See ii The Privacy Act 1988 defines "personal information" to mean information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. iii For the purposes of this White Paper the terms data, records and information are used without distinction. It should be noted that both structured and unstructured information will fall within the ambit of personal information and require compliance with the Act. iv Data governance, an emerging discipline which embodies the convergence of data quality, data management, data policies, business process management and risk management surrounding the handling of data in an organization. Sound data governance means positive control over the processes and methods used by data stewards and data custodians in the handling of data, particularly PI, which is required for compliance with the APPs. v Ref APP 1, (open and transparent management of personal information (PI)) requires reasonable steps to implement practices, procedures, systems and policy that inter alia include how PI is collected, held and disclosed. APP 12 deals with access to PI. vi "sensitive information" means: (a) information or an opinion about an individual's:(i) racial or ethnic origin; or (ii) political opinions; or (iii) membership of a political association; or (iv) religious beliefs or affiliations; or (v) philosophical beliefs; or (vi) membership of a professional or trade association; or (vii) membership of a trade union; or (viii) sexual preferences or practices; or (ix) criminal record; that is also personal information; or (b) health information about an individual; or (c) genetic information about an individual that is not otherwise health information.

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