Privacy
Impact Assessments, or PIAs, are the ideal tool for assessing new initiatives,
whether technical, policy or legislative.
When it comes to PIAs, we can literally say: "we wrote the book". In 2009 we were commissioned by Privacy Victoria to revise and update their
PIA Guide and develop additional practical material. Our revised PIA
Guide and two accompanying practical tools - a template PIA Report and a comprehensive list of common privacy risks and mitigation
strategies - were launched by the Privacy Commissioner in May 2009 to mark Privacy Awareness Week.
In 2010 an international evaluation rated our PIA Guide amongst the best in the world, and said to "stand out as best practice". A 2011 report for the European Commission also reviewed our PIA Guide and accompanying tools and noted their breadth of scope and application.
We believe a PIA should do more than just assess a proposed project’s likely
compliance with statutory privacy principles. It should also assess the privacy
control environment – the policies, procedures and structures which affect
accountability for privacy compliance – and wider community concerns and
perceptions about the initiative.
The
PIA process describes and de-mystifies the initiative, identifies and analyses
the privacy
implications, and leads to recommendations for minimising privacy intrusion,
and maximising privacy protection – while ensuring the initiative’s objectives
are met.
In April 2009 Salinger Privacy was prequalified by AGIMO for streamlined Australian Government procurement in relation to Project Governance, and Business Case Analysis and Development. PIAs may fit into either of these categories.
Significant PIAs we have completed for the Australian Government include:
Department of Families, Housing, Community Services and Indigenous Affairs - on the $1 billion launch of the historic National Disability Insurance Scheme, in conjunction with Minter Ellison Lawyers
Innovation - on the development of a national Unique Student Identifier for the vocational education and training sector, in conjunction with Minter Ellison Lawyers
AusCheck - the development of a generic national security background check
Attorney General's Department - the Anti-Money
Laundering and Counter-Terrorism Financing Bill and Rules
AusCheck - background checking for security and identity cards in the Aviation
and Maritime industries, and
Australian Communications & Media
Authority - the ENUM (Electronic Telephone Numbering) Trial.
PIAs we have completed for the Victorian Government include:
the Victorian Government Department of Primary Industries - on the rollout of smart electricity metering in Victoria, in conjunction with Lockstep Consulting; PIA published here
the Victorian Department of Education and Early Childhood Development, on the $60M Ultranet project
the Victorian Department of Health (HealthSMART
program), on the implementation of its integrated Patient and Client Management
System, in conjunction with Lockstep Consulting, and
VicRoads, on the RandL project, which will provide a common application platform for registration and licensing processes in three agencies. RandL is a large-scale project with a scheduled completion date of late 2012.
Here's what our client said about the benefits of our first PIA for AusCheck:
"The PIA findings and recommendations are a valuable resource to AusCheck and have assisted in the refining and enhancing of AusCheck’s business processes. Documentation of the PIA investigation, analysis, assessment and findings has formed a useful review and decision-making tool for AusCheck."
AusCheck accepted 63 of our 65 recommendations, and were subsequently recognised in the Australian Privacy Commissioner's 2008 Privacy Awards for their commitment to good privacy practice.
To see our second PIA for AusCheck, on the development of a generic national security background check, go to the Attorney General's Department website and look for AusCheck under "All topics A-Z".