Privacy Act Compliance: GRC Solutions Streamline Success

Data Privacy Week offers an excellent opportunity to assess your organisation’s Governance, Risk, and Compliance (GRC) responsibilities. In light of the December 2024 amendment to the Australian Privacy Act 1988, all Australian organisations are now required to take “reasonable steps” to safeguard the data privacy of both current and former customers, in line with the 13 Australian Privacy Principles (APPs). With the Office of the Australian Information Commissioner’s (OAIC) enhanced investigative and enforcement powers—including provisions for civil litigation and possible criminal penalties—organisations should carefully review their policies, procedures, and operational plans to ensure they meet compliance standards.

The latest Notifiable Data Breaches Report (January to June 2024) underscores the importance of these legislative changes. There was a 9% increase in breach notifications from the previous period (July to December 2023), with Health Service Providers with the highest amount of notifications followed by, Australian Government. Finance, Education, and Retail sectors wrapped up the top 5 of all notifications to OAIC. Malicious activity resulted in 67% of data breaches notifications, continuing the long term trend of data breaches being the result of cyber security incidents.

Figure 1: A breakdown of the Cyber Incidents resulting in a data breach from the Notifiable data breaches report covering the January to June 2024 (OAIC)

To demonstrate “reasonable steps” in the event of a data breach, organisations should consult their lawyers for specific advice, but some generals steps include establishing:

• Comprehensive policies and procedures for data collection, handling, storage, and disposal
• Privacy Collection Notices (PCNs) at all PI collection points, detailing the purpose, usage, storage, and disposal of collected information
• Robust data security measures, including encryption, access control, and employee training
• A Incident response plans for managing potential data breaches

A Privacy Impact Assessment (PIA) serves as an essential starting point, ideally conducted alongside risk and security assessments to ensure adequate protection of Personal Information (PI). These assessments should be performed annually to maintain accurate records of PI data locations and systems. While traditional manual assessments typically require several weeks, GRC Software-as-a-Service (SaaS) solutions like Wolters Kluwer, Workiva, and MyCISO streamline this process and facilitate rapid reporting on protective measures.

These platforms, once integrated into your IT infrastructure, enhance compliance visibility and reporting efficiency. They help track PI data locations, monitor access patterns, and expedite incident response and reporting to affected customers and OAIC. With approximately 90% of Australians seeking stronger data protection measures, organisations demonstrating robust privacy practices can establish themselves as industry leaders.

GRC SaaS solutions extend beyond privacy compliance, addressing multiple regulatory obligations through a single platform. These systems facilitate third-party vendor assessments and simplify the ISO/IEC certification process, demonstrating international standard compliance to stakeholders and enhancing organisational reputation. Whether implementing enterprise-scale solutions like Wolters Kluwer and Workiva or utilising MyCISO for small and medium-sized businesses, GRC SaaS platforms provide efficient, cost-effective support for Privacy Act compliance and risk management.

*Organisations with existing ISO/IEC 27001 Information Security Management certification can pursue ISO/IEC 27701 Privacy Information Management certification and enhance both with ISO/IEC 27000 Security Techniques for Privacy Information Management Systems.