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Follow-up of DIBP’s implementation of the recommendations

October 2017

In July 2017, the OAIC conducted a follow-up of the actions taken and progress made by DIBP in response to the recommendations made in the Assessment of Schedule 7 of the Foreign Fighters Act. In September 2017, DIBP provided a response which outlined the ways in which DIBP has implemented the OAIC’s recommendations. The OAIC’s recommendations and DIBP’s response are outlined below:

Recommendation 1 — Ensure policy governance ownership is identifiable

1.1 Assessors recommend that DIBP introduce governance measures to ensure an appropriate level of responsibility and accountability for the oversight and implementation of appropriate practices, procedures and systems for handling personal information in accordance with Schedule 7 of the Foreign Fighters Act. This should include responsibility for:

  1. appropriate training to communicate and educate all affected DIBP staff on the appropriate use of the new power under Schedule 7 of the Foreign Fighters Act
  2. review, and maintenance, of the SOP and PAM3 to ensure clear and consistent guidance is available to affected staff on appropriate procedures for the seizure of bogus document data.

1.2 DIBP accepts this recommendation.

1.3 In October 2015, DIBP established its Identity and Biometrics Division (IBD) to ensure there is enterprise-wide leadership on matters of identity and biometrics. IBD has incorporated information relating to the seizure of bogus documents into existing training programs delivered by FDEs to operational staff. As part of this training, the case officers are provided information regarding the power to seize and the procedures governing the exercise of that power. DIBP has also replaced the SOP and the PAM 3 with updated and specific documentation on the detection, seizure and retention of bogus documents. The OAIC has observed this documentation.

Recommendation 2 — Review bogus document handling practices, procedures and systems for offshore posts

2.1 Assessors recommend that DIBP review its bogus document handling practices, procedures and systems for offshore posts to ensure that appropriate safeguards or standards are implemented across the posts to ensure appropriate personal information protections.

2.2 DIBP accepts this recommendation.

2.3 The OAIC has observed documentation which reflects DIBP review of its document handling practices, procedures and systems in relation to offshore posts.

Recommendation 3 — Establish a document destruction policy for seized documents

3.1 Assessors recommend that DIBP establish a document destruction policy for seized documents.

3.2 DIBP accepts this recommendation.

3.3 The OAIC has observed updated documentation which provides guidance on the storage and retention of seized documents.

3.4 The OAIC considers that DIBP has addressed all three recommendations made in this assessment report.