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OIC NT submission

[Redacted for publication]
[received as email 10 September 2011]

Dear Dimitrios,

The Office of the Information Commissioner (NT) thanks you for the opportunity to comment on the proposed TFN Guidelines, Information Sheet, and Classes document.

PROPOSED GUIDELINES

We have no comment on the Guidelines.  They seem clear and straight forward.

PROPOSED INFORMATION SHEET

We congratulate you on the clear and readable nature of the Information Sheet, given that this is a difficult and technical topic. 

  • We have a couple of suggestions for the Information Sheet:
  • We query the use of technical words in item 4 of part B.  We do not think the average person would be familiar with terms such as ‘data-matching’, ‘data-sharing’ and ‘data-linking’.  We suggest wording these dot points in plainer English, eg:

4 Why is it important to protect the privacy of TFNs?

  • It is important to protect the privacy of TFNs because they are unique identifiers which are issued to individuals for life.
  • Some of the privacy concerns associated with TFNs include:
  • they could potentially be used by all government agencies and private sector organisations as part of a national identification system
  • they could be used to link records of personal information held by many different agencies and organisations, which could:
    • enabling an agency or organisation to look up detailed information about a person just by knowing their TFN;
    • increase the risk of serious breaches of personal privacy if data is misused; and
    • increase the risk of effective identity theft.
  • The example of scanning data in item 9 of Part B is a good one, but it’s not very clear what an organisation is supposed to do at this point.  We suggest the fact sheet should be clearer as to the steps an organisation should then take (seek legal advice?  Store the scanned copy with a certain degree of security? Store a version with the TFN removed?)
  • We would suggest that there be a phone number and/or email address to request more specific advice.  Despite the plain English, the information is quite complex and we expect that many small businesses would struggle to understand the precise nature of their responsibilities.

CLASSES DOCUMENT

The Classes Document is very clear and readable.

 

Regards

Caroline Norrington
Complaints & Policy Officer
Office of the Information Commissioner
GPO Box 3750, Darwin NT 0801
Floor 7, 9-11 Cavenagh Street, Darwin

Telephone: 1800 005 610
Direct: [Redacted for publication]
Fax: [Redacted for publication]

Email: caroline.norrington@nt.gov.au
www.infocomm.nt.gov.au