18 March 2015


The Office of the Australian Information Commissioner has - alongside self-congratulation about the "commitment of a dedicated and skilled group of staff who worked tirelessly" - announced that
The OAIC will release a Privacy management framework during Privacy Awareness Week. This framework will assist entities meet their compliance and accountability requirements in the most efficient manner — through a top-down commitment to embed a culture of privacy and establish robust and effective privacy practices.
PAW is an initiative of the Asia Pacific Privacy Authorities forum (APPA) and is the primary privacy awareness campaign of the Asia Pacific region.
The theme for 2015 is Privacy everyday. Privacy should be an essential component of everyday life, including transactions such as internet banking, social media and online shopping. The theme emphasises the need for organisations to embed privacy practices into business as usual processes, and for individuals and the community to think about how to protect privacy in their everyday lives.
The OAIC has concurrently offered selected entities, on a non-public basis, "an opportunity to comment on a draft" of the Privacy Management Framework. It refers to "selected representatives from private sector organisations and government agencies".

Given recurrent statements by OAIC about the importance of transparency you might expect some disclosure of how the organisation identified the "selected representatives". You would, alas, be disappointed.

The OAIC so far has resisted any disclosure as to how it selects “the selected” and how it determines whether the “representatives” are representative. Privacy everyday, transparency rarely?

Given the OAIC's problematical view of consultation - which it appears to regard as a tiresome matter of form rather than substance and in the past has involved signs of regulatory capture - it is unsurprising to see that if you are one of the fortunate entities chosen for consultation a copy of the draft framework was to be provided on 17 March and that the OAIC "will require comments by COB Tuesday 24 March 2015".

The draft Framework will of course "be provided on a confidential basis".