Australian Privacy Foundation home

The association that campaigns for privacy protections

Selected APF Papers Sorted by Jurisdiction

This document indexes papers according to the jurisdictions to which they are relevant.

Submissions regarding a Non-Government matter appear under the appropriate Non-Government heading, even if they were made to a Federal, State or Territory Parliament or Government Agency.

This index reflects work undertaken by the APF up to 31 December 2015.

The index is comprehensive since 2002. It also includes key documents dating back to 1987,
and papers by APF's sibling organisation the Australian Privacy Charter Council (1994-2002).

See also the chronological index, which is always up-to-date.

A companion document indexes papers by topic-areas. See also the Campaigns pages.


Contents

N.S.W. Private Sector - For Profit
Victoria Private Sector ­ Not For Profit
Queensland Individuals
Western Australia  
South Australia Federal Public Sector – see Policy Topics index
Tasmania  
A.C.T. Trans-Jurisdictional and Trans-Border
Northern Territory International

N.S.W.

  1. Privacy Tort, Submission to NSW Parliamentary Inquiry (15 Dec 2015)
  2. Remedies for Invasion of Privacy, Submission to NSW Legislative Council (23 Sep 2015)
  3. NSW Transport Opal Cards, Submission to NSW Transport Minister (24 Aug 2015), the PC'er's reply (25 Sep 2015) and the completely beside-the-point 'response' from the Minister (7 Oct 2015)
  4. NSW Government Digital Profile Service, Submission to Service NSW (30 Jul 2015)

  5. Engagement with NGOs, Submission to NSW Privacy Commissioner (18 Mar 2014)
  6. Guidelines for Hosting State Government Data Outside NSW Borders, Submission to NSW Privacy Commissioner (16 Mar 2014), and the Commissioner's reply (17 Mar 2014)

  7. The Opel Card, and Anonymous Use of Public Transport, Letter to NSW Transport Minister (29 Sep 2013), and the reply from the Minister (20 Nov 2013)
  8. Review of CCTV Schemes, Submission to NSW Premier and Attorney-General (5 May 2013), and the Premier's dismissive reply (30 May 2013)
  9. Anonymous Travel on the M5, Submission to NSW Minister for Transport (10 Mar 2013)

  10. NSW Transport Opal Card, Letter to NSW Minister for Transport (29 Nov 2012)

  11. Anonymity on Toll-Roads, Letters to the Operators of the Sydney Eastern Distributor and M2 (15 Dec 2011)
  12. Guidelines re Biometrics, Letters to the Privacy Commissioners, in conjunction with Liberty Victoria, NSW CCL, QCCL and CLA (19 Oct 2011):
  13. Electronic Transport Ticketing System, Letter to NSW Minister of Transport (2 Mar 2011), and the Department's Reply (25 Mar 2011)
  14. Review of the Workplace Surveillance Act 2005 (NSW), Submission to NSW Attorney-General's Dept (31 Jan 2011)
  15. Draft NSW Human Rights Bill, Submission to NSW Parliament (18 Jan 2011), and the revised Draft Bill of Rights (4 Feb 2011)

  16. Draft CCTV Code of Practice, Submission to Penrith Council (7 Sep 2010)

  17. Data Linkage between NSW Police and Medicare, Letter to Clth Privacy Commissioner (5 October 2009)
  18. The Healthelink Scheme, Public Statement (28 September 2009)

  19. Evaluation of the Healthelink Records Pilot, Submission to NSW Health Minister Della Bosca (December 2008)
  20. Privacy Legislation in New South Wales, Submission to N.S.W. Law Reform Commission re Consultation Paper 3 (October 2008)
  21. Policy Statement on Road Tolls (Sep 2008)
  22. Anonymous Use of Public Roads and Public Transport, Letter to Privacy and Human Rights Commissioners (September 2008), and a holding reply from NSWPC (October 2008)
  23. N.S.W. Government Travel Smartcard, Letter to the N.S.W. Minister for Transport (September 2008)
  24. Letter of Welcome, to the incoming NSW Privacy Commissioner, Judge Ken Taylor (January 2008)

  25. Letter to Parties re NSW Election regarding their Privacy Platform (March 2007)
  26. Submission to NSW Ombudsman re 'Lockdown powers' Issues Paper, Dec 2006 (February 2007)
  27. Letter to NSW Premier Iemma re appointment of a Privacy Commissioner (January 2007)

  28. NSW Education Bill – an unjustified threat to privacy: letters to Minister and Shadow Minister (14 November 2006)
  29. Access to Court Records, to N.S.W. A/G's (July 2006)

  30. Letter to the NSW Privacy Commissioner (December 2005)
  31. Reply from the NSW Privacy Commissioner (December 2005)
  32. The Documents that the NSW Privacy Commissioner says don't need to remain publicly available (but we do), safely stored on the Wayback Machine:
  33. Analysis of NSW Workplace Surveillance Bill (May 2005)
  34. NSW Minister for Education & Training re Student ID Card Proposal (April 2005)
  35. The NSW Photo Card Bill ‚ How To Fix It (March 2005)
  36. 31 Questions for the NSW Minister for Roads about the Photo Card Bill 2004 (February 2005)
  37. Review of the NSW Photo Card Bill 2004 (February 2005)
  38. NSW Minister for Roads - 2nd Letter re Drivers' Licence Photo Card Bill 2004 (February 2005)
  39. N.S.W. Police re Numberplate Recognition Technology (January 2005)
  40. Letter to the Editor re Beach Cameras (January 2005)

  41. NSW Parliamentarians re State Records Amendment Bill 2004 (October 2004)
  42. N.S.W. Attorney-General re Workplace Surveillance Bill (August 2004)
  43. Subsequent Correspondence with NSW Attorney-General's Dept (19 May 2004)
  44. Summary of Submission to NSW Attorney-General's Dept re Review of NSW Privacy Act (17 May 2004)
  45. Submission to NSW Attorney-General's Dept re Review of NSW Privacy Act (17 May 2004)

  46. NSW Health re Health Records and Information Privacy Act 2002: Draft Statutory Guidelines (November 2003)
  47. Letter to the Opposition and Cross-Benches re the Privacy and Personal Information Protection (Amendment) Bill (NSW), to disestablish the 28-year-old N.S.W. Privacy Commission and in other respects weaken privacy protections (November 2003)
  48. Letter to the NSW Electoral Commissioner (May 2003)
  49. Letter to N.S.W. Liberal Party re Toll Booths (February 2003)

  50. N.S.W. Office of State Revenue on Review of N.S.W. Fines Act (June 2002)
  51. Proposed Code of Practice for disclosures of personal information outside New South Wales, Privacy NSW (May 2001 - APCC)
  52. Submission to a Select Committee of the N.S.W. Parliament on the N.S.W. Privacy and Data Protection Bill 1994 (30 June 1994)

Victoria

  1. Sperm Donor Anonymity, Submission to Victorian Dept of Health (11 Sep 2015)

  2. Privacy and eHealth Records: Victorian Healthcare Service, Letter to OAIC (23 Feb 2014), and the OAIC's action-avoiding response (7 Mar 2014)

  3. Sexting, Evidence to the Victorian Law Reform Committee, mirrored here (10 Dec 2012)
  4. Appointment of a Replacement Privacy Commissioner, Follow-Up Letter to the Attorney-General of Victoria (13 Jul 2012), and the empty reply (27 September 2012)
  5. Sexting, Submission to Victorian Parliament Law Reform Committee (7 Jun 2012)
  6. Appointment of a Replacement Privacy Commissioner, Letter to the Victorian Attorney-General, and his immediate reply (13 Mar 2012)
  7. Infosheet on 'Biometrics and Privacy, Letter to the Victorian Privacy Commissioner (9 Mar 2012) plus annotations; and the Acting Commissioner's reply (27 Mar 2012)

  8. Police Action in Relation to Fairfax, Letter to Victorian Electoral Commissioner (19 Dec 2011), and the reply (21 Dec 2011)
  9. Guidelines re Biometrics, Letters to the Privacy Commissioners, in conjunction with Liberty Victoria, NSW CCL, QCCL and CLA (19 Oct 2011):

  10. iPads for Doctors, Submission to the CIO, Victorian Dept of Health (8 Oct 2010), the CIO's reply (20 Oct 2010), and the APF's further letter (21 Oct 2010)

  11. Disclosure of Personal Data by Victoria Police – submission to the Victorian Privacy Commissioner (8 December 2009), and the OVPC's Media Release (later on 8 December 2009)
  12. Disclosure of Personal Data by Victoria Police – submission to the Victorian Commissioner for Law Enforcement Data Security (8 December 2009), and the Commissioner's evasive 'reply' (14 December 2009)
  13. Disclosure of Personal Data by Victoria Police – submission to the Federal Privacy Commissioner (8 December 2009), and further submission (9 December 2009)

  14. Victoria's Whole of Health ICT Strategy, Letter to the Minister (October 2008)
  15. Policy Statement on Road Tolls (Sep 2008)
  16. Anonymous Use of Public Roads and Public Transport, Letter to Privacy and Human Rights Commissioners (September 2008)

  17. Letter to Victorian Premier Bracks re appointment of a Privacy Commissioner (January 2007)
  18. Victorian Privacy Commissioner re Privacy Impact Assessment Guidelines (February 2005)
  19. Letter to Victorian Police re Strategies for Handling Organised Crime (December 2004)
  20. Vic Law Reform Commission re Workplace Privacy Options Paper (November 2004)
  21. Submission re the Victorian Law Reform Commission's Issues Paper: "Workplace Privacy" (January 2003)
  22. Submission to Victorian Privacy Commissioner's Inquiry on Building Permit information (March 2002 - APCC)
  23. Victorian Data Protection Bill Discussion Paper (January 1999 - APCC) (Victorian Bill 99.doc)
  24. Victorian Data Protection Advisory Council (October 1996 - APCC) (Mvicsb1.doc)

Queensland

  1. CitySafe CCTV and Transmission to iPads, Submission to Brisbane City Council (19 Apr 2014), and the dismissive reply (21 May 2014)
  2. CitySafe CCTV and Transmission to iPads, Submission to Qld Police Minister and Brisbane City Council (14 Mar 2014), and the BCC's Reply (4 Apr 2014)

  3. Appointment of a Replacement Privacy Commissioner, Follow-Up Letter to the Attorney-General of Queensland (17 Jul 2012), and the empty reply (26 July 2012)

  4. Guidelines re Biometrics, Letters to the Privacy Commissioners, in conjunction with Liberty Victoria, NSW CCL, QCCL and CLA (19 Oct 2011):

  5. Queensland Driver's Licence, Letter to Queensland Premier (14 Sep 2010)
  6. Fixed Speed Cameras, Submission to Queensland Parliamentary Economic Development Committee (14 Apr 2010)

  7. Policy Statement on Road Tolls (Sep 2008)
  8. Queensland Driver's Licence, further letter to Qld Premier (June 2008), and the reply (November 2008)
  9. Automated Number Plate Recognition (ANPR), Verbal Evidence to Queensland Parltry Travelsafe C'tee - pp. 10-16 (March 2008)
  10. Biometrics of Visitors to Queensland Correctional Centres, Letter to Qld Minister for Police (March 2008)
  11. Queensland Driver's Licence, Letter to Qld Premier (March 2008), and the Premier's response (May 2008)
  12. Automatic Number Plate Recognition Technology (ANPR), to the Queensland Parliamentary Travelsafe Committee (January 2008)

  13. Biometrics of Visitors to Queensland Correctional Centres, to Qld Minister for Police (October 2007), and the Minister's Reply, p. 1 and p. 2 (November 2007)
  14. Submission re Review of the Queensland Club Industry Privacy Code (October 2005)
  15. Transcript of Evidence to Qld Crime and Misconduct Commission re: Police Radio Communications Access (29 July 2004)
  16. Queensland Crime and Misconduct Commission re: Police Radio Communications Access (June 2004)
  17. Submission to Queensland Transport re the proposed Smartcard-based Driver's Licence (November 2003)

W.A.

[Note: There has never been a privacy-relevant statute in W.A., nor any relevant oversight agency to which a submission could be made ...]

  1. Open Data Policy, Submission to the WA Premier (3 Mar 2015)

S.A.

  1. Fingerprint Collection by SA Police, Letters to SA Premier and SA Leader of the Opposition (18 Feb 2014)
  2. A statutory cause of action for invasion of privacy, Submission to S.A. Law Reform Institute (14 Feb 2014)
  3. 'SA Laboratory exposes hundreds of personal medical details', Interview on ABC PM, mirrored here (18 July 2011)
  4. Anonymous Use of the Adelaide Public Transport System, Letter to the S.A. Transport Minister (October 2008)
  5. Demands for the Identity of Library Users, to the State Library of S.A. (January 2008)
  6. Submission re the South Australian Criminal Law Consolidation (Identity Theft) Amendment Bill 2003 (August 2003)

Tasmania

  1. Electoral matter on the Internet, Letter co-signed with Digital Tasmania, to the Tasmanian Electoral Commissioner (19 Feb 2010)
  2. Letter to the Tasmanian Ombudsman (December 2005)

A.C.T.

  1. Privacy Cause of Action; and Data Retention, Submission to ACT Attorney-General (1 Mar 2015)

  2. Pay Parking Anonymity, Letter to ACT Treasurer (24 Sep 2013), and the fairly positive reply from the Minister (14 Oct 2013)

  3. Point to Point Cameras, Submission to ACT Greens, plus Notes on Mass Surveillance and copy of CCTV Policy Statement (22 Aug 2011)
  4. Point to Point Cameras, Reply from ACT Minister for Transport to ours of 17 July (22 Aug 2011)
  5. Point to Point Cameras, Submission to ACT Shadow Minister for Transport (22 Aug 2011)
  6. Point-to-Point Cameras, Submission to ACT Minister for Transport (17 July 2011)
  7. Smart Electricity Meters, Letter to ActewAGL (20 Jun 2011)

  8. Point-to-Point Cameras (ANPR), Submission to ACT Minister for Transport (21 October 2010), and the Minister's reply (11 Nov 2010)
  9. Possible new Privacy Act for the A.C.T., Submission to A.C.T. Attorney-General, jointly with CLA (30 August 2010)
  10. Disclosure of Criminal Records, Letter to A.C.T. Chief Magistrate (9 August 2010)

  11. Anonymous Use of Public Roads and Public Transport, Letter to Privacy and Human Rights Commissioners (September 2008)
  12. Election Challenge – A.C.T. (September 2008)
  13. RFID-Tagging in the new ACT Prison, submission to ACT Corrective Services Minister (March 2008), and the Minister's response (April 2008)
  14. Publication of CCTV Photos of Passers-By, to AFP and The Canberra Times (December 2007), and reply from the AFP (April 2008)

  15. Swipe Cards in ACT Schools, to ACT Minister for Education (September 2007)
  16. RFID Tagging of Prisoners, submission to A.C.T. Human Rights Commissioner (August 2007), and the Commission's response (December 2007)
  17. RFID-Tagging in the new ACT Prison, submission to ACT Corrective Services Minister (July 2007), and the Minister's response (August 2007)

  18. Terrorism (Extraordinary Temporary Powers) Bill 2005, to ACT Government (January 2006)
  19. Letter to the Federal Privacy Commissioner re the ACT Government (December 2005)

N.T.

  1. Misleading Government Claims re N.T. eHealth Implementation, Letter to the Editor of The Australian (September 2008)

Private Sector – For Profit

This section is concerned with privacy-intrusive actions by corporations, and by industry associations that represent their interests. For specific topics, see also the index to policy-areas.

  1. Copyright Notice Scheme Industry Code, Submission to Communications Alliance (23 March 2015), and CA's response (22 Apr 2015)

  2. Performance audit of ACMA’s regulation of unsolicited communications , Submission to ANAO (30 Nov 2014)
  3. Prepaid Mobile Id Checks, Submission to Dept of Communications (16 Nov 2014)
  4. Engagement with Consumer and Privacy Advocates, Letter to Australian Retail Credit Association (ARCA), with Financial Rights Legal Centre, Consumer Action Law Centre and Financial Counselling Australia (11 Nov 2014)
  5. The Veda Paid Credit Report and VedaScores , Complaint to OAIC, with Financial Rights Legal Centre, Consumer Action Law Centre and Financial Counselling Australia (20 Oct 2014)
  6. Veda Free Credit Report and Marketing, Complaint to OAIC, with Financial Rights Legal Centre, Consumer Action Law Centre and Financial Counselling Australia (20 Oct 2014)
  7. Online Copyright Infringement, Submission to Attorney-General's Dept (5 Sep 2014)
  8. Veda's Provision of Subject Access to Credit Reporting Information, plus App. A, App. B and App. C, Complaint to OAIC, with Financial Rights Legal Centre, Consumer Action Law Centre and Financial Counselling Australia (15 Aug 2014)
  9. Dept of Health Use of SurveyMonkey re PCEHR, Submission to OAIC (8 Aug 2014), the response from the company (9 Aug 2014), and the response from OAIC, useless as ever (22 Dec 2014)
  10. Engagement, Letter to Australian Certified UAV Operators Inc. (ACUO) (8 Mar 2014)
  11. Drones and Privacy, Oral Evidence to the HoR Social Policy and Legal AffairsCommittee, Hansard mirrored here (28 Feb 2014)
  12. Privacy and eHealth Records: Victorian Healthcare Service, Letter to OAIC (23 Feb 2014), and the OAIC's action-avoiding response (7 Mar 2014)
  13. Whois Policy Review, Submission to AuDA (31 Jan 2014)
  14. AML/CTF Customer Due Diligence (CDD) Rules, Submission to Austrac (28 Jan 2014)
  15. Optimal period of registration on the Do Not Call Register, Submission to Dept of Communications (15 Jan 2014)

  16. Cloud Computing Industry Code, Submission to ACS (12 Aug 2013)
  17. PCEHR – FAQ for Clinicians, Public Advisory Statement (11 Aug 2013)
  18. PCEHR – FAQ for Consumers, Public Advisory Statement (11 Aug 2013)
  19. Broadcast Media Regulation, Submission to ACMA (13 Jul 2013)

  20. PIAs for Digital Postal Services, Further Letters to Australia Post and Digital Post Australia (6 Nov 2012)
  21. Review of AMSRO Code, Submission to Association of Market and Research Survey Organisations (AMSRO) (31 Aug 2012)
  22. Do Not Knock Register Bill, Submission to Standing Committee on Social Policy and Legal Affairs (27 Aug 2012)
  23. Face-Blurring on YouTube, Letter to Google (20 July 2012), and the reply (24 Jul 2012)
  24. PIAs for Digital Postal Services, Letters to Australia Post and Digital Post Australia (22 Apr 2012), Australia Post's partial response (8 Jun 2012), and Digital Post's vacuous reply (22 Jun 2012)
  25. Substance Abuse Testing and the Workplace, Policy Statement (31 Mar 2012)
  26. Revocation of the Biometrics Institute Code, Submission to OAIC (21 Mar 2012)
  27. Finkelstein Mostly Welcome, but Fails on Privacy Protection Aspects, Public Statement (7 Mar 2012)
  28. Substance Abuse Testing in the Workplace, Letter to AMEC (7 Feb 2012)
  29. Google Terms and Policies, Letter to OAIC (29 Jan 2012)
  30. Google Terms and Policies, Letter to ACCC (29 Jan 2012)
  31. Policy Statement on Google Terms and Policies (29 Jan 2012)
  32. An Appropriate Public Regulatory Body for Media Privacy, Supplementary Submission to the Independent Media Inquiry (9 Jan 2012)

  33. The Integrated Public Number Database (IPND), Submission to Dept of Broadband, etc. (23 Dec 2011)
  34. Police Action in Relation to Fairfax, Letter to Victorian Electoral Commissioner (19 Dec 2011), and the reply (21 Dec 2011)
  35. Privacy Guidelines for Broadcasters, Letter to ACMA (16 Dec 2011), and ACMA's Reply (22 Dec 2011)
  36. Anonymity on Toll-Roads, Letters to the Operators of the Sydney Eastern Distributor and M2 (15 Dec 2011), and Transurban's reply (3 Jan 2012)
  37. Engagement with Civil Society, Letter to Google (2 Dec 2011)
  38. An Appropriate Public Regulatory Body for Media Privacy, Submission to the Independent Media Inquiry (18 Nov 2011)
  39. Review of ACCAN, Submission to Dept of Broadband, Communications and the Digital Economy (23 Oct 2011)
  40. Biometrics in the Workplace, Policy Statement (15 Oct 2011)
  41. Biometrics, Revised Policy Statement (15 Oct 2011)
  42. Privacy Guidelines for Broadcasters, Submission to ACMA (14 Oct 2011), and ACMA's Response (16 Dec 2011)
  43. Submission as amicus curiae in Roadshow v. iiNet, before the High Court, copy here (7 Oct 2011)
  44. Google+ and Engagement with Civil Society, Letter to Google (15 July 2011)
  45. Google+, Letter to Google (30 Jun 2011)
  46. Smart Electricity Meters, Letter to ActewAGL (20 Jun 2011)
  47. The Collection of Third Party Data Through Networks such as Wifi, Policy Statement (31 May 2011)
  48. Location and Tracking of Individuals through their Mobile Devices, Policy Statement (13 May 2011)
  49. PayPass Contactless Payment Technology, Submission to MasterCard Australia (30 Mar 2011)
  50. Credit Reporting - Exposure Drafts of the Australian Privacy Amendment Legislation, Submission to Senate Committee on Finance and Public Administration (25 Mar 2011)
  51. Engagement Between Google and Privacy Advocates, Letter to Google (26 Jan 2011)

  52. Project Stop (Over-The-Counter Pseudoephedrine Products), Letter to Pharmacy Guild of Australia (9 Oct 2010)
  53. Consequences of Google´s Ongoing Failure to Engage with Civil Society, Letter to Google (27 August 2010)
  54. Urgent Request to Regulators to Demand Return of Google WiFi Data to Australia, letter to ACMA/AGD and OFPC (28 May 2010). The Attorney-General was subsequently reported to have "asked [the AFP] to investigate possible criminal breaches" (ABC News, 6 June 2010, and The Australian, 7 June 2010)
  55. Request to Suspend Deletion of WiFi Data, letter to Google Australia (27 May 2010), forwarded by Google Aust to Google Inc. late on 28 May 2010
  56. Characteristics of a Privacy Professionals' Association, Letter to iappANZ (15 May 2010)
  57. Collection and Use of WiFi-Related Information, Letter to Google Australia (13 May 2010), and Google Australia's reply (19 May 2010). Partly overtaken by Google HQ's Retraction and Apology (14 May 2010), mirrored here. Reported in The New York Times (16 May 2010)
  58. Anti-Counterfeiting Trade Agreement, Accession to the Wellington Declaration (12 April 2010)

  59. eHealth Data and Health Identifiers, Policy Statement (28 August 2009)
  60. eHealth Care Data Breach, Policy Statement (28 August 2009)
  61. Access to Share Registers, to Clth Treasury (21 July 2009)
  62. 'Nurses paid to scout for Vioxx drug firm', to OFPC (May 2009)
  63. Medical Director and AsteRx data, to OFPC (May 2009), and reply (May 2009)
  64. Review of Consumer-related Industry Code Processes, to the Dept of Broadband Communications and the Digital Economy (May 2009)
  65. Re Mobile Premium Services (MPS) Code and Guideline, joint NGO Letters to ACMA, ACCC, and The Minister (March 2009)
  66. ALRC Report Part H – Health, Submission to Clth PM & C (February 2009)
  67. Fair Work Bill, Submission to the Senate Education, Employment and Workplace Relations Committee (February 2009)
  68. Personal Property Securities Bill, Evidence to the Senate Legal & Constitutional C'tee (January 2009), mirrored here

  69. Enforcement of the Do Not Call Register, Policy Update (October 2008)
  70. Policy Statement on Road Tolls (Sep 2008)
  71. Identity Scanning by Registered Clubs, Policy Statement (September 2008)
  72. Google StreetView, Policy Statement (August 2008)
  73. Re Communications Alliance's lack of attention to privacy, APF Letter (9 June 2008), CA's Reply (19 June 2008), and APF's Further Letter (30 June 2008)
  74. Workplace Email, Policy Statement (April 2008)
  75. Google StreetView, Policy Statement (April 2008)

  76. The State of Media Freedom, 2nd submission to ‘Australia’s Right to Know’ Coalition (October 2007)
  77. Unsolicited Commercial Faxes or ‘Fax Spam’, to DCITA (30 August 2007)
  78. Scanning of Identification Documents, submission to Office of the Federal Privacy Commissioner (August 2007)
  79. The State of Media Freedom, submission to ‘Australia’s Right to Know’ Coalition (August 2007)
  80. Use of IPND information to provide Location Dependent Carriage Services (LDCS), submission to DCITA (August 2007)
  81. Tenancy Database Regulations, submission to Cth AGs re Draft Privacy (Private Sector) Amendment Regs (June 2007)
  82. EFTS Code Review, submission to ASIC (May 2007)
  83. Draft Telecommunications (Do Not Call Register) (Telemarketing and Research Calls) Industry Standard Variation 2007: Proposed ‘Sunday call’ variation, Submission to ACMA (May 2007)
  84. Further Dilution of the Do Not Call Register, Submission to ACMA (13 April 2007)
  85. Credit Reporting Provisions, ALRC Issues Paper No. 32 (March 2007)
  86. Access Card: Emergency Medical Info (Discussion Paper #2), to Access Card Taskforce (March 2007)
  87. Submission to NeHTA re UHI Blueprint (March 2007)
  88. Draft Consumer Privacy Code of Practice on RFID in Retail (March 2007)
  89. IPND Scheme and Legislative Instruments, to ACMA and DCITA (March 2007)
  90. Letter to Privacy Commissioner re SWIFT Complaint of Jul/Oct 2006 (February 2007)
  91. Subm. to ALRC privacy review (February 2007)

  92. Breach of Privacy Act by Australian Financial Institutions (through SWIFT), to Privacy Commissioner (October 2006)
  93. Market and Social Research Privacy Code, to AMSRO (October 2006)
  94. Calling Number Display, with CTN, to Communications Alliance (September 2006)
  95. Proposed Telemarketing Standard, to ACMA (September 2006)
  96. Submission to national ID card ('Access Card') task force, with covering letter (July 2006)
  97. SWIFT - disclosures of Australians' financial information without warrant to the USA, to Privacy Commissioner (July 2006)
  98. Do Not Call Register Bill 2006, to a Senate Committee (June 2006)
  99. Charging for unlisted numbers (Silent lines), to OFPC, TIO, ACMA and ACCC (April 2006)
  100. Identity checks for pre-paid mobile phones, to ACMA (April 2006)
  101. Ethical Conduct in Human Research, to NH&MRC (March 2006)
  102. Genetic Testing Policy of the Investment and Financial Services Association Ltd (IFSA), to ACCC (March 2006)
  103. Costs of Consumer Codes, to ACMA (February 2006)
  104. Review of the Spam Act, to DCITA (February 2006)

  105. Application to the ACCC re the ADMA Code (December 2005)
  106. Submission re a Do-Not-Call Register, to DoCITA (November 2005)
  107. Submission to ACIF re the Code for the Handling of Life Threatening and Unwelcome Calls (November 2005)
  108. Submission to the Human Gene Patents and Genetic Testing Advisory Group (November 2005)
  109. Submission re ACMA Consultation Paper: Disclosure of CLI to 190 Service Providers (October 2005)
  110. 'E-tags are another example of surveillance by stealth' (SMH Ope-Ed Piece by Chair Anna Johnston, 25 August 2005)
  111. ACMA re Integrated Public Number Database (IPND) (31 July 2005)
  112. HREOC re Employment Discrimination based on Criminal Records (February 2005)
  113. Aust Communications Authority: Regulatory Issues re VoIP (January 2005)

  114. Review of the Private Sector Provisions of the Privacy Act 1988 (December 2004)
  115. ACIF re Unfair Consumer Contracts (November 2004)
  116. Summary of Responses to APF's Election Challenge to Political Parties, including the ALP, Democrats and Liberals (October 2004)
  117. APF's Election Challenge to Political Parties (August 2004)
  118. Google GMail Service - Letter to Federal Privacy Commissioner (23 April 2004)
  119. Clth Attorney-General re Employee Records (16 April 2004)

  120. Submission to the Australian Casino Association re its draft Privacy Code (May 2003)
  121. Submission to the OFPC on draft Information Sheet: "Taking reasonable steps ...." (January 2003)

  122. Submission to OFPC on draft Information Sheet: Questions and Answers about Privacy and Personal Information that is Publicly Available (December 2002)
  123. Submission to OFPC on Consultation Paper on Privacy - Collection of Publicly Available Personal Information (September 2002)
  124. Letter to Federal Privacy Commissioner (jointly by APCC, APF and ACA) concerning consultation on draft Codes of Practice. (February 2002 - APCC)

  125. Submission to Internet Industry Association on the IIA draft Privacy Code of Practice (October 2001 - APCC)
  126. Draft NPP Guidelines, Privacy Commissioner (July 2001 - APCC)
  127. Code Development Guidelines, Office of the Federal Privacy Commissioner (June 2001 - APCC) (Word97 document, with revision-markings)

  128. Inquiry into the Privacy Amendment (Private Sector) Bill 2000 by the House of Representatives Standing Committee on Legal and Constitutional Affairs (August 2000)
  129. Senate Legal and Constitutional Affairs Committee re Privacy Amendment (Private Sector) Bill 2000 (filename Submission Senate Aug 00) (August 2000 - APCC)
  130. House of Representatives Committee Inquiry re the Privacy Amendment (Private Sector) Bill 2000 (May 2000 - APCC) (Cwth May 00.doc)
  131. Proposed National Privacy Legislation (January 2000 - APCC) (CwthJan00.doc)

  132. Proposed legislation for the protection of privacy in the private sector (October 1999 - APCC) (CwthSept99.doc)
  133. Senate Select Committee on Information Technology Inquiry into Self-Regulation (Senate IT Inquiry.doc) (August 1998)
  134. Senate Legal & Constitutional References Committee's Privacy Inquiry (June 1998 - APCC) (Senate Privacy Inquiry.doc)
  135. Financial System Inquiry (January 1997 - APCC) (Fsisb2.doc)
  136. Financial System Inquiry (the Ralph Review) (October 1996 - APCC) (Fsisb1.doc)
  137. National Childcare Accreditation Council (NCAC) (30 January 1994)
  138. Submission to the House of Representatives Standing Committee on Banking, Finance and Public Administration's Inquiry into Fraud on the Commonwealth (8 July 1992)

Private Sector – Not For Profit

This section is concerned with privacy-invasive behaviours of incorporated associations, charities, etc., but excluding industry associations whose function is to represent the interests of for-profit businesses. For specific topics, see also the index to policy-areas.

  1. Fair Work (Registered Organisations) Amendment Bill 2013, Submission to Senate Education and Employment Committee (10 Feb 2014)

  2. PIAs for Digital Postal Services, Further Letters to Australia Post and Digital Post Australia (6 Nov 2012)
  3. Deployment of Cloud Computing, Follow-Up Letter to Australian National University (6 Nov 2012)
  4. Biometrics at ATMs, Letter to ANZ (6 Oct 2012)
  5. Credit Reporting Reform - Consumer Education, Submission to Clth Attorney_General's Dept (20 Sep 2012)
  6. Deployment of Cloud Computing, Submission to Australian National University (17 Sep 2012), and the ANU CIO's Response (25 Oct 2012)

  7. WhoIs and RCI Policy Reviews, Submission to auDA, and Underlying Analysis (21 Oct 2010)
  8. Project Stop (Over-The-Counter Pseudoephedrine Products), Letter to Pharmacy Guild of Australia (9 Oct 2010)
  9. iPads for Doctors, Letter to Alfred Health, Melbourne (5 August 2010)
  10. The Privacy Policies of Australian Universities, Submission to Universities Australia (14 Apr 2010), and a holding reply (29 July 2010)

  11. eHealth Data and Health Identifiers, Policy Statement (28 August 2009)
  12. eHealth Care Data Breach, Policy Statement (28 August 2009)
  13. Access to Share Registers, to Clth Treasury (21 July 2009)
  14. National Registration of Health Workers, to Senate Community Affairs Committee (April 2009)
  15. Electronic Transfer of Pathology Data, to NEHTA (April 2009)
  16. Policy Statement re Privacy and the Media (March 2009)
  17. Disclosure of Genetic Information Without Consent, Submission to NHMRC (March 2009)

  18. Heart Foundation 2008 ‘Survey’, Letter to the National President, Bruce Carter (November 2008)
  19. Enforcement of the Do Not Call Register, Policy Update (October 2008)
  20. Identity Scanning by Registered Clubs, Policy Statement (September 2008)

  21. Unsolicited Commercial Faxes or ‘Fax Spam’, to DCITA (30 August 2007)
  22. Scanning of Identification Documents, submission to Office of the Federal Privacy Commissioner (August 2007)
  23. Draft Telecommunications (Do Not Call Register) (Telemarketing and Research Calls) Industry Standard Variation 2007: Proposed ‘Sunday call’ variation, Submission to ACMA (May 2007)

  24. Market and Social Research Privacy Code, to AMSRO (October 2006)
  25. HREOC re Employment Discrimination based on Criminal Records (February 2005)
  26. Submission to OFPC on Consultation Paper on Privacy - Collection of Publicly Available Personal Information (September 2002)
  27. National Childcare Accreditation Council (NCAC) (30 January 1994)

Individual

This section is concerned with actions by individuals that intrude on the privacy of others. For specific topics, see also the index to policy-areas.

  1. Drones and Privacy, Oral Evidence to the HoR Social Policy and Legal AffairsCommittee, Hansard mirrored here (28 Feb 2014)
  2. Sexting by Minors, Submission to Senate Select Ctee on Cyber-Safety (24 Jul 2013)
  3. Policy Statement re Privacy and the Media (March 2009)
  4. Tenancy Database Regulations, submission to Cth AGs re Draft Privacy (Private Sector) Amendment Regs (June 2007)
  5. Google GMail Service - Letter to Federal Privacy Commissioner (23 April 2004)
  6. Submission to OFPC on Consultation Paper on Privacy - Collection of Publicly Available Personal Information (September 2002)

Federal Public Sector

This section is concerned with privacy-invasive behaviour by the Commonwealth government. A vast amount of the APF's efforts have had to be spent in this area, partly because of the inherently privacy-invasive nature of some of what government agencies do, but particularly because of the very strong orientation of senior government executives towards central planning and social control, and wilful avoidance of recognising the importance of privacy.

So enormous is the range of issues that the APF has had to deal with that it is of little value to list papers here. Instead, use the index to policy-areas to find relevant documents.


Trans-Jurisdictional and Trans-Border

  1. APEC Cross Border Privacy Rules (CBPR) system, and non-renewal of TRUSTe’s AA status, Submission to APEC, jointly with Samuelson-Glushko Canadian Internet Policy & Public Interest Clinic (CIPPIC), Center for Digital Democracy (CDD), Electronic Privacy Information Center (EPIC), plus further signatories (3 Dec 2014)
  2. Guidelines for Hosting State Government Data Outside NSW Borders, Submission to NSW Privacy Commissioner (16 Mar 2014)

  3. The APEC Cross Border Privacy Rules system, Submission to APEC Data Privacy Subgroup (24 Jun 2013)

  4. Proposed Personal Data Protection Bill, Submission to Singapore Ministry of Information, Communications, and the Arts (MICA) (29 Apr 2012)

  5. Free Trade Agreements (FTAs), including the Proposed Trans-Pacific Partnership Agreement (TPPA), Submission to Department of Foreign Affairs and Trade (7 Sep 2011)
  6. EU-Australia Passenger Name Record (PNR) Agreement, Further Comments (27 Sep 2011)
  7. EU-Australia Passenger Name Record (PNR) Agreement, Public Statement (19 Sep 2011)
  8. Review of the 1980 OECD Guidelines, Submission by the Civil Society Information Society Advisory Council (CSISAC) to the OECD (4 April 2011)

  9. Cross Border Data Transfers, Submission to Dept of Prime Minister & Cabinet (30 November 2009)
  10. Privacy Principles & Interstate Disclosure – GQ v NSW DET [2008] NSWADT 3191, Letters to NSW Privacy Commissioner & ors. (January 2009)

  11. Letter to Privacy Commissioner re SWIFT Complaint of Jul/Oct 2006 (February 2007)

  12. Breach of Privacy Act by Australian Financial Institutions (through SWIFT), to Privacy Commissioner (October 2006)
  13. SWIFT - disclosures of Australians' financial information without warrant to the USA, to Privacy Commissioner (July 2006)

International

  1. French Mass Surveillance Bill, Endorsement of Letter to the French Assembly, and another, mirror here (30 Sep 2015)
  2. Data Retention in Peru, Signup to Access Now Statement, mirrored here (17 Aug 2015)
  3. Defence Trade Controls Act (DTCA), Endorsement of Petition by International Association for Cryptologic Research (IACR), mirrored here (14 Jul 2015)
  4. Promote Strong Encryption and Anonymity in the Digital Age, Sign-up to Human Rights Watch Submission to the UN Human Rights Council (17 Jun 2015)
  5. Data Retention Bill, Sign-on to an Open Letter to the Paraguay Senate (2 Jun 2015), and a report on the defeat of the Bill (5 Jun 2015)
  6. The European Council's Data 'Reform' Package, Submission to European Commission (21 Apr 2015)
  7. Surveillance in Australia, Submission to United Nations Human Rights Council, in conjunction with the US Center for Democracy & Technology (CDT) (prime author), NSW CCL and Privacy International (24 Mar 2015)
  8. The Use of Encryption and Anonymity in Digital Communications, Submission to UN High Commissioner for Human Rights (10 Feb 2015)
  9. Privacy advocates win significant improvements in APEC Cross Border Privacy Rules (CBPR) (29 Jan 2015)

  10. APEC Cross Border Privacy Rules (CBPR) system, and non-renewal of TRUSTe’s AA status, Submission to APEC, jointly with Samuelson-Glushko Canadian Internet Policy & Public Interest Clinic (CIPPIC), Center for Digital Democracy (CDD), Electronic Privacy Information Center (EPIC), plus further signatories (3 Dec 2014)
  11. CoE Convention 108 Additional Protocol and Modernisation Proposals, Submission to Council of Europe Convention 108 Committee (17 Nov 2014)
  12. Proposed Changes to Japanese Privacy Law, Submission to the Japanese government (24 Jul 2014)
  13. The 'Trans-Pacific Partnership' (TPP), Sign-on to Open Letter (4 Jul 2014)
  14. Opposition to Recognition of TRUSTe as a CBPR Accountability Agent, Submission to APEC (13 Jun 2014)
  15. Democratic Control of Surveillance by the State, Policy Statement (10 May 2014)
  16. Trans-Pacific Partnership (TPP), Submission to Dept of Foreign Affairs and Trade (13 Mar 2014)

  17. Investigation and Control of Australian Spy Agencies Essential, Public Statement (4 Dec 2013)
  18. ASD Disclosures of Personal Data to Foreign Countries, PI Complaint to Human Rights Commissioner (2 Dec 2013)
  19. ASD Disclosures of Personal Data to Foreign Countries, PI Complaint to Inspector-General of Intelligence & Security (2 Dec 2013)
  20. UN Draft Resolution re Privacy in the Digital Age, Letter to the Minister for Foreign Affairs, and the Attorney-General (17 Nov 2013), and the reply from Foreign Affairs (not the Minister) (16 Dec 2013)
  21. UN Draft Resolution re Privacy in the Digital Age, Letters to the 9 Human Rights, Privacy and Information Commissioners (17 Nov 2013), and the reply from the AHRC (28 Nov 2013)
  22. International Data Privacy Standards, Revised Policy Statement (17 Sep 2013)
  23. Internet Governance, Letter to IT for Change Coalition (28 Aug 2013)
  24. International Data Privacy Standards, Policy Statement (3 Aug 2013)
  25. International Principles on the Application of Human Rights to Communications Surveillance, Sign-on to International Instrument (31 Jul 2013)
  26. TRUSTe's Accountability Agent Application, Submission to APEC Joint Oversight Panel (8 May 2013)
  27. Application from TRUSTe for recognition as an APEC CBPR Accountability Agent, Submission to APEC CBPR (11 Mar 2013)

  28. Free Trade Agreements (FTAs), including the Proposed Trans-Pacific Partnership Agreement (TPPA), Submission to Department of Foreign Affairs and Trade (7 Sep 2012)
  29. Proposed Personal Data Protection Bill, Submission to Singapore Ministry of Information, Communications, and the Arts (MICA) (29 Apr 2012)
  30. The US President's Privacy White Paper, Submission to the US Administration (14 Apr 2012)
  31. Review of the Council of Europe Convention, Submission to Consultative Committee re the CoE Convention (28 Mar 2012)

  32. EU-Australia Passenger Name Record (PNR) Agreement, Further Comments (27 Sep 2011)
  33. EU-Australia Passenger Name Record (PNR) Agreement, Public Statement (19 Sep 2011)
  34. Review of the 1980 OECD Guidelines, Submission by the Civil Society Information Society Advisory Council (CSISAC) to the OECD (4 April 2011)

  35. Anti-Counterfeiting Trade Agreement, Accession to the Wellington Declaration (12 April 2010)

  36. Global Privacy Standards for a Global World, Signatory to International Declaration (14 October 2009), mirrored here

  37. Secret Provisions of the Anti-Counterfeiting Trade Agreement (ACTA) Must be Made Public, Sign-on to an international movement (September 2008)
  38. Re the OECD Ministerial Meeting on The Future of the Internet Economy, Commentary, and Letter to the Minister for Broadband etc. (June 2008)
  39. Report on Discussions re the APEC Privacy Initiative (February 2008)

  40. Declaration of Civil Society Organizations on the Role of Data Protection and Privacy Commissioners, to the Commissioners, in Montréal (25 September 2007)
  41. Letter to Privacy Commissioner re SWIFT Complaint of Jul/Oct 2006 (February 2007)

  42. Breach of Privacy Act by Australian Financial Institutions (through SWIFT), to Privacy Commissioner (October 2006)
  43. SWIFT - disclosures of Australians' financial information without warrant to the USA, to Privacy Commissioner (July 2006)
  44. Extradition Law and Practice, to Attorney-General's Dept (April 2006)

  45. Signon to International Public Interest Movement Request to Google to Suspend Gmail (24 April 2004)
  46. Letter to the E.U. regarding misleading assurances by the Australian Government re the protection of Passenger Name Record (PNR) data, and detailed letter to the Attorney-General (5 April 2004)
  47. Recommendations for Improvements to APEC Privacy Principles [HTML] (19 March 2004)

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Created: 26 December 2004 - Last Amended: 8 January 2016 by Roger Clarke - Site Last Verified: 11 January 2009
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