In WA, some projects now need a privacy assessment before they start.
In WA, switching on a new system that touches personal information may now require a formal assessment first. Not after go-live.
WA’s new Act makes Privacy Impact Assessments mandatory in defined circumstances. Where a function or activity involves handling personal information that is likely to have a significant impact on the privacy of individuals, a PIA must be completed before the entity first performs that function. The Information Commissioner can also direct that one be done.
This changes the sequence. A PIA is no longer a nice-to-have attached at the end of a project. For higher-impact activities, it is a precondition to starting. New technology deployments are the obvious trigger: a new case management system, an analytics platform, an AI tool that processes personal information. The report must, at a minimum, assess how likely the activity is to affect privacy and how significant that effect would be.