Privacy-enhancing information sharing: Practical tips from the Commissioner
Information sharing has been a significant issue for the Victorian public sector over the past few years. We have recently seen a number of new laws and programs implemented to enable easier, more efficient information sharing across government, such as a new family violence information sharing scheme and the establishment of the Victorian Centre for Data Insights.
Information sharing can present complex challenges for privacy, data security and public access to information. The Office of the Victorian Information Commissioner (OVIC) is committed to assisting Victorian public sector agencies to navigate these questions.
When faced with an information sharing initiative, keep in mind these three tips:
Rethink the role of privacy law: privacy law is sometimes perceived as a barrier to information sharing, but generally this is not the case. Victoria’s Privacy and Data Protection Act 2014 contains mechanisms that enable individuals’ personal information to be shared in certain situations, from Information Privacy Principle (IPP) 2.1, to the ‘flexibility mechanisms’ that permit departures from the IPPs where there is a substantial public interest in doing so.
Be aware of other peoples’ perspectives: every Victorian will have a different perception of what privacy means to them. For some, information sharing will be seen as a business as usual practice of government and they may even expect that government is sharing information about them to deliver streamlined services. For others, such as victims of family violence who are escaping their perpetrator, information privacy will be fundamental to their own safety and wellbeing. Think beyond your own experiences to imagine how your agency’s initiatives will impact others.
Engage with OVIC early: OVIC is here to help. Agencies should engage with OVIC on any upcoming information sharing initiative – whether it be a program, policy or legislation. Early engagement provides the opportunity to work together to ensure strong privacy and security protections, while allowing agencies to achieve your their objectives.
This article was written by Sven Bluemmel, Information Commissioner, and originally appeared on the Law Institute of Victoria website.