Privacy Management Diagnostic
-
The Privacy Management Diagnostic helps organisations independently assess how well they manage personal information in line with privacy law and community expectations.
It identifies strengths, risks, and improvement opportunities across your privacy governance, operational practices, and data lifecycle — from collection to disposal.
This diagnostic provides a structured, evidence-based assessment that informs compliance with the Privacy Act 1988 (Cth), aligns with the Australian Privacy Principles (APPs), and supports broader trust and risk management initiatives.
-
The assessment draws on:
• The Australian Privacy Principles (APPs) — core legal obligations under the Privacy Act
• Notifiable Data Breaches (NDB) scheme — requirements for breach detection and reporting
• OAIC guidance on privacy governance and accountability
• International frameworks such as ISO/IEC 27701 and the GDPR (for multi-jurisdictional alignment)
• Industry practice for data governance, security, and lifecycle management
-
1. Governance and Accountability
Assesses whether privacy is governed at the right level within the organisation, including board oversight, privacy officer responsibilities, and risk integration.
2. Policy and Transparency
Reviews privacy policies, notices, consent processes, and external communication of data practices.
3. Collection and Use of Personal Information
Evaluates how data is collected, justified, and used, ensuring it is necessary, proportionate, and within scope of consent.
4. Data Quality and Accuracy
Assesses controls for keeping personal information accurate, up to date, and relevant to its purpose.
5. Storage, Security, and Access Controls
Examines physical, technical, and procedural safeguards to protect data from unauthorised access, modification, or disclosure.
6. Disclosure and Cross-Border Data Handling
Evaluates how third-party sharing and overseas disclosures are assessed and managed, including contractual controls.
7. Access and Correction Rights
Assesses how individuals can access and correct their information and whether processes align with APP obligations.
8. Retention and Disposal
Reviews how personal information is securely destroyed or de-identified when no longer required.
9. Data Breach Preparedness and Response
Assesses detection, escalation, and reporting processes for potential or actual breaches, including compliance with the Notifiable Data Breaches scheme.
10. Training and Awareness
Evaluates how staff understand and apply privacy principles, from onboarding through ongoing communication and culture.
11. Data Governance and Integration with Cybersecurity
Examines the relationship between privacy and security functions, ensuring coherent data protection across technology, policy, and operations.
12. Emerging Obligations and Readiness
Explores preparedness for new privacy reforms, cross-sector frameworks, and obligations like the Consumer Data Right (where relevant).
-
You’ll receive three key outputs at the conclusion of the diagnostic:
1. Privacy Maturity Snapshot
A clear visual summary showing your current privacy maturity across governance, process, and operational control dimensions.
2. Evidence Pack
Structured record of interviews, policy reviews, and documentation, ready for use in board or regulator discussions.
3. Roadmap for Uplift
Prioritised recommendations to strengthen governance, policy, and operational controls, with practical next steps to improve compliance and trust.
-
Effort depends on organisation size and privacy complexity:
• Small organisations: 2–3 contributors (Privacy Officer, Operations Lead) over 1 week
• Medium organisations: 3–5 contributors (Privacy, Legal, IT, HR) over 2 weeks
• Larger or regulated entities: 5–8 contributors over 2–3 weeks
The adaptive process targets only the areas where evidence is needed, reducing review time while maintaining depth.
-
Traditional privacy audits are often compliance-heavy and expensive.
This diagnostic provides independent assurance through an intelligent, principle-based assessment that’s faster, more actionable, and proportionate to your organisation’s size and risk profile.
• Independent: Objective insight, not legal or consultancy advice
• Adaptive: Focuses effort on real risks and evidence gaps
• Actionable: Builds a clear roadmap to improve privacy maturity
-
This is not a legal compliance audit or a substitute for formal legal advice.
It does not conduct forensic data analysis or penetration testing.
Instead, it evaluates how well your organisation’s governance, processes, and culture support privacy compliance and accountability.
-
• Organisations preparing for OAIC review or internal audit
• Businesses handling sensitive or large-scale personal information
• Boards and executives seeking assurance over privacy management and risk
• Consultants supporting client readiness or data governance uplift