Across 2-3 December, the IAPP ANZ Summit was held in Sydney – the largest ever gathering of privacy professionals in our region, with more than 500 attendees. The Helios Salinger team was out in force, catching up with old friends, making new connections, and welcoming young professionals into the fold. For our final blog of…
Is identifiability in the eye of the beholder? EU case tests limits of pseudonymisation
In Australia, our information privacy rights turn on the threshold definition of ‘personal information’. If data meets the definition of ‘personal information’, there will be privacy obligations attached to it; otherwise, all bets are off. The components of the definition include that the information must be ‘about an individual’, and that the individual must be ‘identified ……
Mind the gap: when legal permission is not enough to ensure compliance
A recent NSW case illustrates the complexity of obtaining lawful authority to disclose personal information – and the equal importance of on-going vigilance, to ensure compliance. Rather than privacy compliance being determined with a single assessment about lawful authority to proceed, I often think that project initiation should involve a set of four cascading assessments:…
Why “Don’t worry it’s de-identified” should (still) be a red flag when considering privacy risk
‘Fingers crossed’ is not smart business strategy. The Privacy Commissioner’s report into I-MED shows that to pursue innovation and compliance, getting de-identification right is complex – but worth it. Last month’s Office of the Australian Information Commissioner (OAIC) report into I-MED’s disclosure of patient records to an AI company should not be seen as permission…
How to get ahead of the new ADM rules before they rule you
Are you across the new Automated Decision-Making transparency requirements? Getting ready to comply with the changes will take time, so organisations should start now. Many of the first tranche privacy reforms passed in December 2024 require organisations to tighten up their practices. In particular, the new rules regarding transparency and Automated Decision-Making (ADM) systems require…
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