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Mandatory Tools & Artefacts · Privacy Act stream

Updated Privacy Policy

Updated 10 Dec 2025

Under the new Schedule 2 to the Privacy Act, the APP 1 privacy policy becomes the public-facing artefact for ADM transparency. It must be updated before the 10 December 2026 commencement and kept current.

Key obligations

  • Add an ADM section listing the kinds of personal information used.
  • Describe the kinds of decisions made solely or substantially by automated means.
  • Specifically call out decisions that have a legal or similarly significant effect.
  • Explain how individuals can seek information about, or challenge, an automated decision.
  • Review and refresh whenever new ADM systems are introduced.

Key dates

  • 10 Dec 2026Updated APP 1 privacy policy must be live.

Who is affected

  • Every APP entity that uses or plans to use ADM with personal information.
  • Includes vendors providing ADM as a service to APP entities — your customers will need disclosures from you.

Source documents

Information is general in nature and not legal advice. Always confirm with the source documents and your own legal counsel.