Your employees are using AI tools with personal information. Are the APPs being met?
AI tools processing personal information without proper governance expose your organisation to Privacy Act penalties of up to AUD 50 million. Aona discovers Shadow AI, enforces privacy-compliant policies, and provides the audit trail the OAIC expects.
The Australian Privacy Principles apply to all handling of personal information — including when employees use AI tools the privacy team has never assessed.
APP 3 requires that organisations only collect personal information that is reasonably necessary for their functions or activities. When employees use AI tools to process customer records, support tickets, or HR data, they may collect personal information in ways that go beyond what is reasonably necessary — sharing entire documents with AI when only specific data points are needed.
APP 6 restricts the use and disclosure of personal information to the primary purpose for which it was collected, or a directly related secondary purpose the individual would reasonably expect. Entering personal information into AI tools for purposes beyond the original collection purpose — such as using customer data to train AI models — may breach APP 6.
APP 11 requires organisations to take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. When personal information is shared with AI tools — particularly those without proper security controls, encryption, or data retention policies — the organisation may fail to meet APP 11's security requirements.
APP 1 requires organisations to manage personal information in an open and transparent way, including having a clearly expressed and up-to-date privacy policy. As AI tools become part of business operations, privacy policies and governance frameworks must address how AI tools handle personal information, what data is shared with AI vendors, and how individuals can exercise their privacy rights.
The Notifiable Data Breaches scheme requires organisations to notify affected individuals and the OAIC when a data breach involving personal information is likely to result in serious harm. AI-related incidents — such as personal information exposed through an AI service breach, or sensitive data stored by an AI tool without proper controls — may trigger NDB obligations.
Employees are adopting AI tools faster than privacy teams can assess them. These tools frequently handle personal information of Australian individuals without the safeguards the Privacy Act requires.
Employees routinely use US-based AI tools like ChatGPT and Gemini to process personal information of Australian individuals. APP 8 requires organisations to take reasonable steps to ensure overseas recipients comply with the APPs — but most employees are unaware of these obligations when using AI.
Many AI tools adopted by employees lack appropriate privacy policies, data retention controls, or transparency about how they handle personal information. APP 1 requires organisations to manage personal information openly — but Shadow AI tools operate outside this governance framework.
When employees enter customer or employee personal information into AI tools, the individuals whose data is being processed may not have been informed or given consent for this use. This creates a gap between the organisation's privacy commitments and its actual data handling practices.
Purpose-built AI security that addresses the Privacy Act compliance challenges of enterprise AI adoption in Australia.
Aona maps every AI tool in use across your organisation and identifies which ones are processing personal information of Australian individuals. Get a complete inventory of AI tools, their data flows, and whether they meet the requirements of the Australian Privacy Principles.
Define and enforce AI usage policies that align with the APPs. Control which AI tools are approved for use with personal information, block personal data from entering unapproved tools, and ensure data minimisation principles are applied automatically — not just through training.
Every AI interaction involving personal information is logged with full context. Generate audit reports that demonstrate compliance with the APPs, support NDB scheme assessments, and provide the evidence the OAIC expects during investigations or reviews.
Enforce data residency requirements for AI tools processing Australian personal information. Aona identifies which AI vendors store data offshore, tracks cross-border data flows, and helps you meet APP 8 obligations for overseas disclosure of personal information.
Discover Shadow AI, prevent personal information exposure, and demonstrate APP compliance — all from one platform.