Ai Group welcomed the opportunity to make a submission on the Discussion Paper for the Review of the Privacy Act 1988 (Cth) by the Attorney-General’s Department (AGD). This submission follows on from our previous submission on the Issues Paper to the AGD in November 2020.

We note that the Issues Paper stage provided the AGD with an opportunity to start the conversation regarding areas in which the Privacy Act Review could cover in a holistic way. The Discussion Paper has now been released which includes potential options to reform the Privacy Act.

However, at this time we have not yet been provided with a Regulation Impact Statement (RIS) and details of the proposed timeline for implementation of the proposed reforms. Given the extensive nature of the proposed reforms and wide-ranging impact on businesses, we submit that a significant transition period will be required should these reforms proceed.

In reviewing the Discussion Paper, including various proposals and questions, we consider that the volume of material needs to be properly worked through with stakeholders.

Given the extensive review and wide implications that proposals arising from the review could have on many businesses, we propose that the AGD consider breaking down their proposals into a more digestible and manageable manner, to allow sufficient time to be considered practically. This will ensure that stakeholders are properly engaged.