December 2023
FOIREQ25/00487 001
Summary of risks and recommendations
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These APPs will be considered below.
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APP 5 requires that at or before the time, or if that is not practicable, as soon as practicable after, the
OAIC collects personal information about an individual, the OAIC must take such steps (if any) as are
necessary in the circumstances to:
1. notify the individual of the matters in APP 5.2; or
2. otherwise ensure that the individual is aware of any such matters.
Compliance
In relation to the context of the user metrics being gathered, APP 5.2(b)(ii) requires notification if the
individual is not aware that personal information is being collected. Even though no personal
information will be collected in the process, save for IP addresses which will be de-identified, the fact
that the collection will happen through the tool will be indicated in the privacy policy. Additionally,
APP 5.2(d) indicates the purposes for which personal information is being collected. This would be
mentioned in the privacy policy for the purpose of producing analytical reports to help improve
services being provided by the OAIC. APP 5.2(i) indicates whether personal information is likely to be
disclosed to overseas recipients, and APP 5.2(j) indicates those countries. Given that all data gathered
will be anonymised and de-identified before being transferred overseas, this would be complied with.
However, the privacy policy will mention this fact as well.
Risks and mitigations
If the OAIC does not update the privacy policy to indicate that data will be gathered for reporting and
analysis, then there be a risk of breaching APP 5. The following recommendations will mitigate any
risks.
Recommendations
It is recommended that the OAIC:
1. update the privacy policy to indicate what data is being gathered by GA4, including:
a. device IP address (collected and stored in an anonymized and de-identified format);
b. search terms and pages visited on the website;
c. date and time when pages were accessed;
d. downloads, time spent on page and bounce rate;
e. referring domain and out link, if applicable;
f. device type, operating system and browser information;
g. device screen size; and
h. geographic location (city); and
2. update the privacy policy to indicate which OAIC websites will be using GA4; and
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3. include a notice on those websites in the form of banner or otherwise visible form to indicate that
by browsing and interacting with the OAIC websites, that the users have read, understood and
agree with the privacy policy, consider whether this notice should be presented as click-wrap
form rather than browser-wrap; and
4. indicate in the privacy policy and the notice that GA4 will be used, and specify which websites will
be using the tool, including the purpose for which GA4 will be used, and what information will be
gathered.
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