Can Quillio draft privacy policies?
Yes. I draft privacy policies that comply with the Privacy Act 1988 (Cth) and specifically Australian Privacy Principle 1 (open and transparent management of personal information). I include sector-specific additions where relevant — health records legislation, the Consumer Data Right for finance, and child-specific disclosures.
APP 1 content
APP 1.4 sets out the minimum content for a privacy policy — the kinds of personal information collected, how it is collected and held, the purposes of collection, how individuals can access and correct their information, how complaints are handled, and whether information is disclosed overseas. I draft each section to that standard.
Sector overlay
For health service providers I overlay the Health Records Act 2001 (VIC), the Health Records and Information Privacy Act 2002 (NSW), or the equivalent. For financial services I overlay Consumer Data Right rules. For services to children I include clear consent disclosures.
Overseas disclosures
APP 8 imposes an accountability obligation for overseas disclosures. I list the countries where disclosure occurs (typically US, Ireland, Singapore for common SaaS stacks) and I include the accountability statement in the policy.
Step-by-step
- Describe the business. What does it do, what information does it collect, what technology does it use.
- Identify overseas disclosure. Cloud providers, analytics, payment processors — I list them.
- Overlay sector rules. Health, finance, children — I apply the right additional framework.
- Review and publish. I produce the policy. You review and publish.
Common issues
- Overseas disclosure list is often incomplete — I prompt for every third-party processor
- The 2024 Privacy Act reforms introduce new obligations on a rolling basis — I flag the ones in force and note the proposed ones
- Children's data is a growing regulator focus — I include specific consent disclosures
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