All Questions Data & Privacy Is it necessary for our business to have a privacy policy for our website as well as a separate policy for our employees?
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Is it necessary for our business to have a privacy policy for our website as well as a separate policy for our employees?


Yes, we'd typically recommend that you have a privacy policy for your website, and a separate internal privacy 'manual' for employees.

Website Privacy Policy: The Online Standard

The Privacy Act 1988 (Cth) mandates that organizations that deal with personal information must have a transparent and accessible privacy policy. This policy should detail how your firm collects, uses, stores, and discloses personal information (Privacy Act 1988 (Cth) - Sect 14). Specifically, it should address:

  • The types of personal information collected
  • The purposes of collection
  • How the information is collected and held
  • The ways in which the information is used and disclosed
  • The process for an individual to access and correct their personal information
  • How an individual may complain about a breach of the APPs and how the complaint will be handled
  • Whether the personal information is likely to be disclosed to overseas recipients

Creating this document is not only a compliance measure but also a trust-building tool that assures your clients and site visitors that their data is handled with the utmost care and respect.

Employee Privacy Manual: A Dual-Purpose Guide

For internal purposes, an employee privacy manual should exist as a distinct document. This internal policy should elaborate on how your firm processes and safeguards the personal and sensitive information of your employees in line with the APPs and the Fair Work Act 2009 (Cth), ensuring workplace rights and privacy are respected.

Additionally, this manual must provide explicit guidance to your employees regarding the handling of client information. This should cover:

  • Secure handling and processing of client information
  • Access controls and authorizations
  • Protocols for the storage, transfer, and destruction of sensitive data
  • Obligations under the Privacy Act 1988 (Cth) and other relevant legislation like the Notifiable Data Breaches (NDB) scheme
  • Employee training programs on privacy and data security
  • Reporting structures for potential privacy issues or breaches
  • Regular updates in line with changes in privacy law and technology

By instituting a comprehensive privacy policy for your website and a detailed internal privacy manual for your employees, you affirm your firm’s commitment to protecting personal information, thereby reinforcing your reputation and compliance with Australian law.

Both documents should be living documents, subject to regular review and updates to reflect changes in legislation, such as amendments to the Privacy Act or new rulings related to data protection and employee rights.

Ensuring these policies are well-documented, accessible, and communicated will help maintain transparency with your clients, fulfill legal obligations, and safeguard your firm’s integrity in the handling of sensitive data.

Alex is Sprintlaw’s co-founder and principal lawyer. Alex previously worked at a top-tier firm as a lawyer specialising in technology and media contracts, and founded a digital agency which he sold in 2015.

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