Observations
Privacy Policy Template
The following Template is consistent with the Australian Government’s Privacy and Responsible Information Sharing Act 2024 and the Freedom of Information Act 1992. While this Template contains many examples of best practice privacy management, it is expected that many organisations will lie on a spectrum of privacy maturity. Organisations will need to customise the following template to reflect their current plans and their target state.
1. Privacy Policy – Purpose and Scope
[Organisation Name] is committed to protecting personal information. This policy outlines how we collect, store, process, and share personal and sensitive data, including the role of artificial intelligence (AI) technologies in this process. It also outlines how AI is integrated into our services, the safeguards we put in place, and your rights as an individual.
2. What Personal Information Do We Collect
[Organisation Name] undertakes a range of operations requiring the collection of personal information, including (for example):
- Customer inquiries.
- Providing services, e. g. aged care, water distribution, health services, and community facilities.
- Assessing development and major project applications.
- Recording, investigating, and managing complaints and allegations.
- Health and compliance certification.
- Incident management.
- Issuing leases, approvals, consents, licences, and permits.
- Employment and fitness for work.
We collect the following types of personal information, including data used to train or operate AI systems:
Identity and Contact Information
- Name, address, phone number, email, date of birth, and other identifying details. May be used to verify identity, manage user accounts, and communicate with individuals.
Demographic and Profile Data
- Age, gender, preferences, language, and accessibility settings. May be used by AI to personalise user experiences.
Behavioural and Interaction Data
- Clicks, page views, time on site, content engagement, and transaction history. May be used in AI models to predict user interests or detect unusual activity.
Device and Technical Data
- IP address, device type, operating system, browser type, geolocation, and session metadata. Enables fraud prevention, system optimisation, and AI-based analytics.
Sensitive Information
- Health, biometric, or racial. Strictly limited and protected under legislation and internal controls.
3. How We Collect Data
- Information is collected in various formats, including:
- Hardcopy
- Electronic and web forms
- Recorded meetings
- CCTV
- Direct interactions through sign-up forms, surveys, and online account creation.
- AI-driven interactions, including responses from chatbots and automated systems.
- Website cookies and third-party analytics tools to track user preferences and behaviours.
- Partner organisations and third-party integrations, where permitted.
4. How We Use Personal Information – Including AI
Personal information may be used for:
-
Core Service Delivery
- To provide products or services as requested.
- To maintain records and administer accounts.
-
Personalisation and Recommendations
- AI is used to tailor content, offers or support, based on user preferences and past behaviour.
-
Automated Decision-Making
- In limited cases, AI may assist or automate decisions (e. g. fraud detection, support triage).
- We inform individuals when this occurs and provide options for human review when required by law.
-
Product and Process Improvement
- Aggregated, de-identified data may be used by AI to improve algorithms and customer experience.
- We do not use identifiable personal information for these purposes unless explicitly permitted.
-
Compliance and Risk Management
- AI may help detect cyber security threats, financial irregularities, or policy breaches.
- Includes real-time monitoring and alerting systems.
5. How We Store and Protect Personal Information
We are committed to data security, with extra safeguards for AI-influenced data environments.
Data Security Measures
- Encryption: all sensitive data is encrypted during transmission and storage.
- Access Controls: multi-factor authentication and restricted access policies ensure only authorised personnel handle sensitive data.
- Secure Infrastructure: we utilise advanced security protocols, including firewalls, regular vulnerability assessments, and cyber security threat monitoring.
Data Governance and Lifecycle Management
- Data is retained only as long as necessary for its intended purpose.
- AI training data is reviewed for bias, accuracy, and compliance with retention requirements.
- Personal data is not used to train third-party AI models without consent or de-identification.
AI-Specific Controls
- Datasets used for AI are anonymised or pseudonymised where possible.
- Bias detection tools are used to mitigate unfair or discriminatory outcomes.
- Model outputs are tested to ensure explainability, especially when decisions affect rights or entitlements.
6. How We Share Personal Information
We may share personal information under strict conditions:
With Trusted Service Providers
- Includes Cloud providers, service providers, and consultants.
- Sharing of personal information is bound by contracts with third parties requiring data security, privacy protection, and no unauthorised use.
With Regulatory or Legal Authorities
- To comply with legal obligations, subpoenas, or enforce our rights.
- We verify requests and seek to limit the scope of disclosure.
Within Corporate Group or Partners
- For operational needs and service integration.
- Subject to intra-group data sharing agreements and privacy safeguards.
7. Your Rights and Choices in an AI Context
Subject to relevant regulations, you have the right to:
- Access your personal data and receive a copy.
- Request corrections if your data is inaccurate or incomplete.
- Withdraw consent at any time for processing based on consent.
- Request deletion of your data, subject to legal limitations.
- Object to or restrict automated decision-making, including AI decisions that produce legal or similarly significant effects.
- Request human intervention in AI-based decision-making processes.
You can exercise your rights by contacting our Privacy Officer (see Contact Us, Section 10).
8. AI Transparency and Ethical Use
We are committed to the use of ethical AI by applying the following principles:
- Transparency: we explain when AI is used and how it impacts you.
- Fairness: we audit AI systems to identify and mitigate bias.
- Accountability: our AI usage is governed by internal oversight and external standards.
- Privacy by Design: AI systems are developed and deployed with privacy embedded throughout the lifecycle.
- Human Oversight: where feasible, important AI decisions are reviewed by human staff.
9. Changes to This Policy
We reserve the right to update this policy periodically to reflect changes in technology, law, or business practices. When updates are material, we will notify you through appropriate channels. The most recent version will always be available on our website, with the date of the last update indicated.
Last Updated: [Insert Date]
10. Contact Us
If you have any questions or concerns about this Privacy Policy or our handling of your personal information, please contact:
Privacy Officer
[Company Name]
[Company Address]
Email: [privacy@[yourdomain].com]
Phone: [+61 XXX XXX XXX]
Next Steps
The rapid adoption and evolution of AI-based applications mean that CIOs and Privacy Officers must stay on top of this technology and its implications for their organisation. We recommend that CIOs and Privacy Officers:
- Review their current Privacy Policy against the Privacy Template and identify any key gaps.
- Consider communicating their approved Privacy Policy via their website and other communications channels
- Ensure that their employees, partners, and other stakeholders are aware of their responsibilities under the Privacy Policy.
