Privacy Impact Assessment Template

Describe the Project and Personal Information

A privacy impact assessment records how a project could affect people’s privacy and what you plan to do about it. Start before choosing a supplier or rolling out a workflow, while you can still change how it works.

Name the change and the people it affects. For each step, enter the information categories and explain why you need each one. The fictional example is a trial that extracts income and expense totals from bank statements. Loan applicants, joint applicants and people named in transactions could all be affected. The totals are needed for review. The processor can do that step without the raw descriptions of individual transactions.

Use category names in the template. Discuss the proposed workflow with the staff who will use it and consider whether you need input from affected people. The Office of the Australian Information Commissioner’s assessment guide explains when to assess a project and who to consult.

Map Collection, Access and Disclosure

Add a flow for each step where information changes hands, is accessed or is kept. Record where it comes from, how it is used and which roles can see it. List the immediate recipients and any subcontractors. Identify where originals, outputs and backups sit, when they are removed and who removes them.

In the example, applicants submit statements through the brokerage’s document portal. The draft names the processor and its support subcontractor, and keeps storage locations and overseas handling unknown. Record known details and mark each remaining uncertainty as unknown or unconfirmed. The example creates follow-up actions for storage, overseas handling and supplier deletion. Its separate supplier question asks the brokerage owner to confirm the subcontractor’s access and deletion terms.

Record countries for hosting and remote access when you know them. Check the supplier’s terms and subcontractor list for onward sharing. Under Australian Privacy Principle 8, before a covered organisation discloses personal information overseas, it generally must take reasonable steps to ensure the recipient follows the applicable principles. Whether an arrangement amounts to disclosure depends on who can access the information and who retains effective control.

Identify Impacts and Practical Controls

Describe what could happen to people at each step and choose a control that addresses that impact. In the example, the processor could see private purchases if staff send full transaction descriptions. The brokerage already limits access to originals. It proposes removing transaction descriptions before transfer and testing that approach on fictional records.

Record confirmed safeguards under Implemented safeguards. Put a measure you still need to test under Proposed control. If you clear the example’s proposed control, the action register asks you to choose a control or alternative. Its count tracks open form actions. The project still needs its own assessment against the Australian Privacy Principles that apply.

Australian Privacy Principle 11 requires covered organisations to take reasonable steps to protect personal information they hold. When the information is no longer needed for an allowed purpose, reasonable steps to destroy or de-identify it are generally required. Record any applicable legal retention requirement before setting a deletion date.

Export the Assessment and Action Register

The assessment combines the project description with the flow summary, impact and control register and open actions. Give each flow an action owner. The example opens with five actions assigned to the brokerage owner. If the same flow needs different people to follow up, edit the individual owners in the draft.

Copy the assessment or download it as an editable text file. Both use the text shown in the editor. Once you edit it, the form leaves your changes in place. Choose Rebuild from form to replace that text, or Reset example to restore the fictional inputs and their draft.

Save the assessment with the project record. Add a due date and completion evidence for each action. Review the flows again if the project changes the information it collects, the supplier arrangements or who can access the records.