How does the organisation currently manage privacy? Show where the change that the project involves will fit with your current systems. 2. Scope of the PIA 2.1 Scope Describe what the PIA covers and what it doesn’t cover. For example: What parts of the organisation, project, systems, or IT infrastructure are included? What are the information-management processes that the PIA will consider (such as use, storage, access, retention and disposal)? What are the limitations of the PIA? For example, it might not cover the use of personal information by a third party if there is no direct control or agreement in place to manage the relationship. 2.2 The process Describe how the PIA was done. For example: What types of information were used? Who was involved? Was anyone outside the organisation consulted? 2.3 Explain the scope and process Describe the rationale for the scope of the PIA and for the process that was followed. 3. Personal information Identify and describe the type of personal information involved and what is happening with it.
Each row in the following table summarises the key requirements of each of the privacy principles and outlines some key questions or considerations you should address. A risk assessment table can help you identify the privacy risks relevant to your initiative. The accompanying Risk and Mitigation Table (see Appendix B) provides a more detailed explanation of how the project fits with the privacy principles. Either cut and paste from the Risk and Mitigation Table into this section of the PIA Report (and then omit those details from the “Risk assessment” section of this report, to save repetition), or provide a brief overview here and then expand on it in the “Risk assessment” section. It is useful to consider the privacy principles even if your agency is one of the few that doesn’t have to comply with the Privacy Act (for instance, if you’re a news agency collecting, using or publishing information for news purposes; or you’re a court or tribunal exercising judicial functions). Your activity may be legally compliant, but understanding how the Privacy Act deals with a matter can better inform you as to the likely privacy impacts of your proposal, and how privacy concerns can best be accommodated. # Description of the privacy principle (These can be deleted from your final report if they’re not relevant to your project – but you should at least consider each principle) Summary of personal information involved, use and process to manage Assessment of compliance Link to risk assessment (if required) 1 Principle 1 - Purpose of the collection of personal information Only collect personal information if you really need it Identify each element of personal information and satisfy yourself that it is necessary for the project. What is the purpose of collecting the personal information involved here? How will that enable the organisation to do what it needs to do? Are you only collecting what you actually need? For example, do you really need “date of birth”, or will “age” or “over 18” be enough? Note for each principle whether the project complies or risks being non-compliant 2 Principle 2 – Source of personal information Get it directly from the people concerned wherever possible How is the information collected, and who from? If personal information is collected from some source other than the individual, is this appropriate and justifiable?
3 Principle 3 – Collection of information from subject Tell them what information you are collecting, what you’re going to do with it, whether it’s voluntary, and the consequences if they don’t provide it. How will you tell people everything in this checklist? Or will it be so obvious to them that you don’t need to it out? If you’re not going to be open with them about what you’re doing, which of the exceptions allows you to keep it from them? Many of these aspects should be covered in any privacy statements or policy that relate to information collection. 4 Principle 4 – Manner of collection of personal information Be fair and not overly intrusive in how you collect the information This should describe how the information is collected, and should assess whether the method of collection is fair and appropriate in the circumstances
7 Principle 7 – Correction of personal information They can correct it if it’s or have a statement of correction attached This section should consider how the organisation will deal with a request for personal information to be corrected or for a statement of correction to be attached Are there limitations? (for instance character limits in data fields; or lack of ability to add a flag indicating there is relevant information held on a physical file) 8 Principle 8 – Accuracy etc. of personal information to be checked before use Make sure personal information is correct, relevant and up to date before you use it Reasonable steps will vary depending on the information involved. Relevant factors include: what process is there to check that information is correct? Has the information been supplied by the individual directly? Has it been checked with the individual directly? Is it automated, or do you have the ability to apply human judgment? How damaging will it be to the individual if information is wrong or misleading? (The more damaging it will be, the more extensive should the steps be for checking accuracy)