Class B Cemetery Trust stakeholders
In Victoria there are over 400 Class B Cemetery Trusts (Class B CTs) managed by community members, often in a voluntary capacity. These Class B CTs are public boards that manage public cemeteries and deliver services with care and compassion.
It is OVIC’s position that Class B CTs under the Cemeteries and Crematoria Act 2003 (Vic) are considered to be public entities for the purposes of the Public Administration Act 2004 (Vic) and therefore are subject to Part 4 of the Privacy and Data Protection Act 2014 (Vic) (PDP Act).
OVIC’s Information Security Unit (ISU) engaged the Department of Health (DH) and Class B CTs to discuss a regulatory approach for the Class B CTs. It is clear from these discussions that volunteers are passionate about protecting trust information including hard copy and soft copy (digital / electronic) information, and verbal discussions.
To address the unique governance arrangements and challenges that volunteer Class B CTs face, OVIC has drafted bespoke reporting requirements specifically for Class B Cemetery Trusts. We understand that some of these requirements may be unfamiliar, and we encourage you to review the resources on this page, and if further support is needed you can speak with a member of the ISU.
What obligations do Class B CTs have under Part 4 PDP Act?
To review the full list of obligations for Class B CTs click here.
What’s required in 2026?
Protective Data Security Plan
In 2026, Class B CTs are expected to submit a Protective Data Security Plan (PDSP) to OVIC, which includes an Attestation signed by the Chairperson or an authorised representative. This PDSP documents the development of an information security program that addresses the protection of Class B CT information.
What do we mean by ‘Information Security’?
Information security is a risk management process that protects public sector information and systems, including Class B Cemetery Trust records, from unauthorised access, disclosure and use. This aims to ensure the right people have access to the right information at the right time.
What does the 2026 PDSP submission cover?
When completing a 2026 PDSP, a Class B CT should consider information security activities that are currently planned, underway or implemented.
When is the 2026 PDSP submission due to OVIC?
A Class B CT must submit a copy of its PDSP to OVIC between 1 July 2026 and no later than 31 August 2026.
How to access a copy of the 2026 PDSP form for Class B CTs
A copy of the 2026 | Class B Cemetery Trust PDSP is now available for download as a Word document or PDF document.
To request a hard copy in the mail, please contact OVIC’s ISU.
How to submit a copy of the 2026 PDSP form
PDSP submissions can be made to OVIC by email (electronic) or mail (paper). For more information on how to submit a PDSP, please read the 2026 | How-to Guide: Protective Data Security Plan (PDSP) for Class B Cemetery Trusts as a Word document or PDF document.
Incident notification
A Class B CT should contact OVIC at its earliest convenience if it becomes aware of any issues impacting the security of its information.
The confidentiality, integrity and/or availability of Class B CT material must be maintained to ensure the continued security of trust information. If you are unsure whether you have experienced an incident, or if you are unsure of how to notify OVIC, please contact the ISU.
An example of an information security incident may be where:
- a trust member mistakenly discloses sensitive information (confidentiality)
- trust records have been altered to misrepresent burial plots (integrity)
- an asset register goes missing (lack of availability)
Resources for Class B CTs
Class B Cemetery Trusts: Information Asset Register
As outlined in the Class B CT PDSP, trusts should develop and maintain an Information Asset Register (IAR) to help identify the different information it manages. An IAR helps the Class B CT develop a comprehensive list of the types of information the trust generates, holds and manages. Developing and maintaining an IAR will help the trust keep a consistent record of its information for current and future members.
OVIC has developed an IAR template specifically for Class B CTs with an accompanying How-to Guide.
Information Asset Register template:
- Word document (best for creating a digital copy) – Click here to download
- PDF document (best for printing a hard copy) – Click here to download
Guide: How to build an Information Asset Register
- Word document – click here to download
- PDF document – click here to download
Class B CTs are not required to provide a copy of their IAR to OVIC unless requested. For more information, please contact OVIC.
Class B Cemetery Trusts: Considering third-party providers
A third-party provider can be any person or organisation outside the Class B CT, that may store or manage any / all trust information on its behalf.
The below information sheet below offers some considerations for Class B CTs in this instance.
- Word document – coming soon
- PDF document – coming soon
Contact OVIC
Call: 1300 006 842 (1300 00 OVIC)
Email: security@ovic.vic.gov.au
Department of Health cemetery sector governance support
Visit the Department of Health Cemetery Sector Governance Support page for more guidance.
Last updated:19 December 2025
