Privacy Law Reform in Australia: What the 2024 Changes Mean for Governance Teams

Privacy reform is often discussed as though it were mainly a legal drafting exercise. For organisations, it is much more than that.

The Privacy and Other Legislation Amendment Act 2024 is one of the most significant updates to Australia’s privacy framework in years. For governance teams, its practical effect is not limited to compliance advice or policy review. It raises the importance of clearer accountability, better internal documentation, stronger issue escalation, and more disciplined handling of privacy risk.¹ ²

Key takeaways

• Privacy reform in Australia is already in force, not merely proposed.¹
• OAIC has described the change as a significant step for Australian privacy law.¹
• APP 1 remains central because it points to real internal governance arrangements, not just public statements.²
• PIAs become more strategically important in a stronger privacy environment.³ ⁴
• AI adoption increases the urgency of disciplined privacy governance.⁵ ⁶

The reform is no longer theoretical

The Act passed Parliament in late November 2024 and received Royal Assent in December 2024. OAIC materials note that the majority of the amendments to the Privacy Act within the Information Commissioner’s remit commenced on 11 December 2024.¹

This matters because privacy reform in Australia is no longer just a consultation topic. Organisations are already operating in a changed environment.¹

The OAIC has signalled the importance of the changes

When the legislation passed, the OAIC described it as a significant step for Australia’s privacy law.¹

The OAIC also noted that the reforms would strengthen the regulator’s enforcement toolkit and online privacy protections for children.¹ Even without unpacking every legal amendment, that is a clear signal that the direction of travel is toward a more robust privacy framework and a more capable enforcement environment.

For governance teams, this means privacy risk should not be treated as a background matter handled only when a complaint or incident arises. Stronger privacy enforcement expectations increase the value of having a repeatable process for identifying issues, assigning responsibility, documenting decisions, and evidencing follow-through.¹

APP 1 still matters operationally

One of the most important principles for governance teams is still APP 1, which requires open and transparent management of personal information.²

This principle is often read as a policy obligation, but in practice it points to a broader operating requirement. Organisations need internal arrangements, decision processes, and governance structures that support good privacy management in a way that is real rather than merely documented.²

That means privacy compliance is not only about publishing the right words externally. It is also about whether the organisation can actually show how privacy risks are identified, reviewed, managed, and escalated internally.²

Why PIAs become more important after reform

The OAIC continues to recommend that organisations conduct privacy impact assessments as part of risk management and planning processes.³ ⁴

A PIA is not simply a form to complete when required. The OAIC describes it as a systematic assessment of a project that identifies privacy impacts and recommends how to manage, minimise, or eliminate them.³

In a stronger privacy environment, that matters more. PIAs provide a structured way to identify issues early, record reasoning, and connect project decisions to privacy obligations. They also help organisations move privacy review upstream, before implementation choices are fixed.³ ⁴

Common governance weaknesses reform tends to expose

These are not only process problems. They become compliance and accountability problems when scrutiny increases.¹ ² ³

AI has made privacy governance more urgent

Privacy reform is landing at the same time many organisations are experimenting with AI tools, automated processes, and more complex data flows.

The OAIC’s AI guidance makes clear that privacy law applies to these technologies. The OAIC has said, as a matter of best practice, that organisations should not enter personal information, especially sensitive information, into publicly available generative AI tools because of the significant and complex privacy risks involved.⁵ ⁶

That means governance teams increasingly need processes that can deal with projects that are not neatly contained within one legal or operational category. A use case may require privacy review, AI risk review, internal approval, security input, and executive visibility.⁵ ⁶

A practical checklist for governance teams

Governance leaders should now be asking:

• Are privacy reviews happening early enough?² ³
• Is ownership clear for actions, risks, and recommendations?
• Can the organisation reconstruct how a significant decision was made?
• Are assessments consistent across teams?
• Is there a reliable way to produce reporting for leadership and assurance stakeholders?
• Are AI-related privacy risks being assessed explicitly?⁵ ⁶

The governance opportunity

Privacy reform is often framed only as a burden. In reality, it can also be a forcing function for better internal discipline.

Organisations that respond well usually do more than update legal documents. They improve the quality of execution. They make privacy reviews more structured. They reduce ambiguity around who is responsible. They strengthen evidence and traceability. And they build a more repeatable operating model for high-risk work.¹ ² ³

Conclusion

The Privacy and Other Legislation Amendment Act 2024 matters because it sharpens the case for stronger privacy governance in practice.

The organisations that will respond best are not just the ones with the best legal interpretation. They are the ones that can show how privacy risk is identified, reviewed, managed, and documented through day-to-day operating processes.¹ ² ³

References

1. OAIC, Passage of Bill a significant step for Australia’s privacy law.
2. OAIC, Australian Privacy Principle 1 — open and transparent management of personal information.
3. OAIC, Guide to undertaking privacy impact assessments.
4. OAIC, 10 steps to undertaking a privacy impact assessment.
5. OAIC, Guidance on privacy and the use of commercially available AI products.
6. OAIC, Guidance on privacy and developing and training generative AI models.