Privacy New Years resolution: Updating your privacy policy

It has been almost three years since the Australian Privacy Principles (APPs) were introduced. At that time many organisations did a widespread review and update of their privacy policies and other key privacy documents and procedures. In a world where fast-evolving technologies regularly impact information collection practices, another review and update may well be (over)due.

APP 1 requires organisations bound by the Privacy Act 1988 (Cth) (Privacy Act) to have a privacy policy that is clearly expressed, up-to-date and one that accurately describes how they manage personal information. An up-to-date privacy policy is not just about complying with your privacy obligations; privacy policies may also be representations by an organisation that are governed by consumer law. You don't want to mislead your customers because your published privacy policy contains outdated or inaccurate information about how you handle their personal information.