Record 03 Quality · APP 10
Keeping customer records accurate
APP 10 requires an organisation to take such steps (if any) as are reasonable to make sure the personal information it collects is accurate, up to date and complete, and that the personal information it uses or discloses is accurate, up to date, complete and relevant, judged against the purpose of that use or disclosure. What counts as reasonable depends on the circumstances, and the OAIC says a step is not excused only because it would be inconvenient, time-consuming or cost something.
Not legal advice. The OAIC (Office of the Australian Information Commissioner) publishes the guidelines this page follows; they are listed at the foot of this page.
WhenTwo moments in a record’s life
The OAIC’s guidelines start from the person: “Handling poor quality personal information can have significant privacy impacts for individuals.” They place the duty at two distinct points: when the information is collected, and when it is used or disclosed. Between those points, regular reviews of the information held may also help keep it accurate, up to date, complete and relevant by the time it is used.
For a customer file, that maps onto two familiar events: the moment a new contact is entered, and the moment a record is pulled up to send an invoice, make a call or pass details to someone else.
How muchWhat “reasonable steps” turns on
The guidelines list the circumstances that set the level of effort:
| Circumstance | What the guidelines say |
|---|---|
| Sensitivity | More rigorous steps may be required for “sensitive information” or other personal information of a sensitive nature. |
| The entity | Its size, resources and business model. An entity that “gives database and network access to contractors” may need different steps from a centralised one. |
| Consequences | More rigorous steps may be required as the risk of adversity to the person increases. |
| Practicability | Time and cost count, but not as an excuse on their own; the question is whether the burden is excessive in all the circumstances. |
At the other end, it can be reasonable to take no steps at all, for example where information comes from a source known to be reliable, such as the person themselves. The guidelines add: “It is the responsibility of the entity to be able to justify that this is reasonable.”
Paragraph 10.8The OAIC’s reasonable steps, as a checklist
Paragraph 10.8 of the guidelines gives examples of steps an entity “could consider”. They are examples, not a mandatory list, and they read naturally against a customer file.
- Practices and systems, with staff trained in them, to audit, monitor, find and fix poor quality information.
- Collecting and recording information in a consistent format, and where practicable noting when it was collected, the point in time it relates to, and whether it is an opinion.
- Adding updated or new information promptly to the existing record.
- Giving people a simple way to review and update their information on an ongoing basis, such as an online portal.
- Reminding people to update their information each time the entity deals with them.
- Contacting the person to check the information when it is used or disclosed, particularly after a long gap since it was collected.
- Checking that a third party supplying the information has appropriate quality practices, which could include an enforceable contract or due diligence before collecting.
- Before using information for a new purpose that was not the primary purpose of collection, assessing its quality for that new purpose.
The second item is the one a record system makes easy or hard. A date beside each detail and a mark on anything that is an opinion are both, in the OAIC’s framing, ways to help judge whether information is still up to date.
PurposeRight for one job, wrong for another
Quality is measured against the purpose of the use or disclosure, so a record “may be of poor quality having regard to one purpose for which it is collected, used or disclosed, but not another”.
The guidelines’ own example of incompleteness is a tenancy database that records a tenant owes a debt that has since been repaid. The record was true once. Used to report defaults, it now gives a partial picture. Their example of relevance is a client file built for financial advice: when the entity later discloses details to buy shares for the client, it should disclose only the parts relevant to that purpose.
Completeness can justify asking for more. Where an entity has to collect additional information to make a record complete for its purpose, the guidelines treat that collection as reasonably necessary for its functions or activities under APP 3.
An opinion can still be accurate. For APP 10, the guidelines say an opinion may be “accurate” if it is presented as an opinion and not as objective fact, accurately records the view held, and is an informed assessment.
AfterwardsAfter a record is fixed
Two follow-ups appear in the guidelines. Where an entity amends a record or adds new information to comply with APP 10, it should consider whether it needs to destroy or de-identify other personal information it holds under APP 11, such as a copy of the old information. And beyond answering requests, an entity should proactively give people a simple means to access and update their information on an ongoing basis.
Access and correction support this duty: seeing their information lets a person spot what is inaccurate, out of date, incomplete or irrelevant.
When a customer does spot an error, the rules move to correcting a customer’s record. When the record feeds a program that decides something for the business, accuracy meets the newer duty in automated decisions and your privacy policy.