16/10/2026
Government agencies are increasingly collecting, sharing and analysing personal information to deliver services, improve decision-making and meet community expectations. As digital services, data sharing initiatives and emerging technologies become more common, agencies face increased scrutiny regarding how personal information is handled. A Privacy Impact Assessment (PIA) is an important tool for identifying and managing privacy risks before they materialise.
A well-prepared PIA can help identify privacy risks early, support compliance with privacy obligations and build public trust in government initiatives. Below are five key considerations for government agencies when undertaking a PIA.
1. Does the Project Require a PIA?
Not every project requires a PIA. Section 12(1) of Privacy (Australian Government Agencies – Governance) APP Code 2017 provides that agencies must conduct a PIA for all high privacy risk projects.
Examples of higher-risk projects include those involving:
- sensitive information, such as health, biometric or criminal history information;
- large volumes of personal information;
- new or emerging technologies, including artificial intelligence and automated decision-making;
- information matching or data-sharing activities;
- surveillance, monitoring or tracking technologies; or
- significant changes to existing systems, programs or business processes.
Before commencing a full PIA, agencies should undertake a Privacy Threshold Assessment (PTA). A PTA is a preliminary assessment that helps determine whether a project raises privacy issues and whether a full PIA is required. Conducting a PTA early can help agencies identify higher-risk projects and allocate resources more effectively.
2. Map the End-to-End Information Lifecycle
A common challenge in privacy assessments is focusing on a single stage of the information lifecycle rather than understanding the complete picture.
To conduct a meaningful PIA, agencies should document and analyse the end-to-end flow of information, including:
- what information is collected, how it is collected and for what purposes;
- who can access it and from what locations;
- how it is used and disclosed; and
- how it is stored, secured and how long it is retained.
A comprehensive understanding of the information lifecycle often reveals privacy risks that may not be apparent when individual business processes are considered in isolation. Mapping information flows early in the project lifecycle supports a privacy by design approach by allowing agencies to identify and address privacy risks before systems and processes are finalised.
3. Have the Right Stakeholders Been Engaged?
Agencies should also ensure key stakeholders, including the Privacy Officer, information security teams, project managers and business owners, are involved throughout the PIA process.
Many government projects also rely on external stakeholders such as third-party providers to deliver technology platforms, cloud services or operational support. A key question for any PIA is whether third parties will have access to personal information.
In some cases, a third party’s access to personal information may constitute a disclosure of personal information. Agencies should ensure these arrangements are clearly documented, assessed and supported by appropriate contractual, operational and technical controls.
4. Is It Necessary to Handle Personal Information?
Agencies should carefully consider whether all proposed collections of personal information are required. In some circumstances, de-identified, anonymised or aggregated information may be sufficient to achieve the intended outcome.
Agencies should also consider whether the amount of personal information collected can be reduced, whether collection can be limited to particular stages of a project, and whether retention periods can be shortened.
Applying data minimisation principles can reduce privacy risks, improve compliance outcomes and lessen the impact of a potential data breach.
5. Are There Any Issues That Require Additional Analysis?
Most PIAs assess privacy risks against the Australian Privacy Principles (APPs). However, some additional analysis may need to be included in the PIA:
- upcoming changes to the Privacy Act or program-specific legislation;
- consideration of relevant legislation such as when sharing information with state, territory or local government agencies;
- projects involving artificial intelligence or automated decision-making;
- whether handling of personal information is required by specific legislation; and
- data matching and cross-agency information sharing.
Where a project raises a particular privacy concern, agencies should identify the issue and request a deeper assessment as part of the PIA process. Addressing complex issues early can help avoid delays, redesign costs and compliance challenges later in the project lifecycle.
Conclusion
A PIA should not be viewed as a compliance exercise undertaken at the end of a project. The most effective PIAs are completed early, informed by a clear understanding of how information will be handled throughout the life of a project. Sometimes, a large project may require more than one PIA during its planning and implementation.
Before commencing a PIA, agencies should:
- complete a Privacy Threshold Assessment;
- identify key stakeholders across business, privacy, legal and technology teams;
- document information flows and data holdings;
- identify third-party providers and information-sharing arrangements;
- review applicable legislative and policy requirements; and
- engage privacy specialists early to achieve privacy by design.
