![]() procedures for identifying and managing privacy risks at each stage of the information lifecycle, including collection, use, disclosure, storage, destruction or de-identification.Whether these factors make it unreasonable to take a particular step will depend on whether the burden is excessive in all the circumstances.ġ.7 The following are given as examples of practices, procedures and systems that an APP entity should consider implementing: However, an entity is not excused from implementing particular practices, procedures or systems by reason only that it would be inconvenient, time-consuming or impose some cost to do so. A ‘reasonable steps’ test recognises that privacy protection must be viewed in the context of the practical options available to an APP entity. the practicability, including time and cost involved.For example, the reasonable steps expected of an entity that operates through franchises or dealerships, or gives database and network access to contractors, may differ from the reasonable steps required of a centralised entity Relevant considerations include an entity’s size, resources and its business model. More rigorous steps may be required as the risk of adversity increases the possible adverse consequences for an individual if their personal information is not handled as required by the APPs.More rigorous steps may be required as the amount and sensitivity of personal information handled by an APP entity increases the nature of the personal information held.The reasonable steps that an APP entity should take will depend upon circumstances that include: An entity could consider keeping a record of the steps taken to comply with APP 1.2, to demonstrate that personal information is managed in an open and transparent way.ġ.6 The requirement to implement practices, procedures and systems is qualified by a ‘reasonable steps’ test. The purpose of APP 1.2 is to require an entity to take proactive steps to establish and maintain internal practices, procedures and systems that ensure compliance with the APPs. enable the entity to deal with inquiries or complaints from individuals about the entity’s compliance with the APPs or such a code.ġ.5 APP 1.2 imposes a distinct and separate obligation upon an APP entity, in addition to being a general statement of its obligation to comply with other APPs.ensure the entity complies with the APPs and any binding registered APP code (see Part IIIB), and.Implementing practices, procedures and systems to ensure APP complianceġ.4 APP 1.2 requires an APP entity to take reasonable steps to implement practices, procedures and systems relating to the entity’s functions or activities that will: APP entities will be better placed to meet their privacy obligations under the Privacy Act if they embed privacy protections in the design of their information handling practices. take reasonable steps to make its APP Privacy Policy available free of charge in an appropriate form (APP 1.5) and, upon request, in a particular form (APP 1.6).ġ.3 APP 1 lays down the first step in the information lifecycle – planning and explaining how personal information will be handled before it is collected. ![]() have a clearly expressed and up-to-date APP Privacy Policy about how the entity manages personal information (APP 1.3 and 1.4).take reasonable steps to implement practices, procedures and systems that will ensure the entity complies with the APPs and any binding registered APP code, and is able to deal with related inquiries and complaints (APP 1.2).This enhances the accountability of APP entities for their personal information handling practices and can build community trust and confidence in those practices.ġ.2 APP 1 imposes three separate obligations upon an APP entity to: 1.1 The declared object of APP 1 is ‘to ensure that APP entities manage personal information in an open and transparent way’ (APP 1.1).
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