Australian Privacy Act
Australian federal law regulating personal information handling
ISO 27018
International code of practice for PII protection in public clouds.
Quick Verdict
Australian Privacy Act mandates privacy compliance for Australian entities via APPs and NDB, enforced by OAIC with heavy fines. ISO 27018 voluntarily guides cloud providers on PII controls within ISO 27001. Organizations adopt the Act for legal duty, 27018 for cloud trust.
Australian Privacy Act
Privacy Act 1988 (Cth)
Key Features
- 13 principles-based Australian Privacy Principles (APPs)
- Mandatory Notifiable Data Breaches (NDB) scheme
- Accountability for cross-border disclosures (APP 8)
- Reasonable steps security and retention (APP 11)
- OAIC enforcement with multimillion penalties
ISO 27018
ISO/IEC 27018:2025 Code of practice for cloud PII protection
Key Features
- Extends ISO 27001 with cloud PII privacy controls
- Requires subprocessor transparency and disclosure
- Prohibits PII secondary use without consent
- Mandates breach notification to customers
- Supports data subject rights fulfillment
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
Australian Privacy Act Details
What It Is
Privacy Act 1988 (Cth) is Australia's primary federal regulation for personal information handling by government agencies and private sector organizations. It establishes a principles-based framework via the 13 Australian Privacy Principles (APPs), covering collection, use, disclosure, security, and individual rights, with a risk-based 'reasonable steps' approach enforced by the OAIC.
Key Components
- **13 APPsGovernance (APP 1), collection (APPs 3-5), use/disclosure (APPs 6-9), integrity/security (APPs 10-11), rights (APPs 12-13).
- NDB scheme for breach notifications.
- Special regimes for credit reporting, TFNs.
- No formal certification; compliance via audits, investigations.
Why Organizations Use It
- Legal compliance for entities over $3M turnover or handling sensitive data.
- Mitigates penalties up to $50M/30% turnover.
- Enhances risk management, trust, cross-border flows.
- Builds reputation, enables data-driven business.
Implementation Overview
- Phased: gap analysis, policy design, controls, training, audits.
- Applies economy-wide, scalable by size/risk.
- OAIC guidance, no certification but assessments required. (178 words)
ISO 27018 Details
What It Is
ISO/IEC 27018 is an international code of practice extending ISO/IEC 27001 and ISO/IEC 27002 specifically for protecting personally identifiable information (PII) processed by public cloud service providers (CSPs) acting as PII processors. Published in editions including 2014, 2019, and latest 2025, it addresses cloud-specific privacy risks like multi-tenancy, subprocessors, and cross-border flows through risk-based controls and implementation guidance.
Key Components
- Approximately 25–30 privacy-specific controls mapped to ISO 27001 Annex A themes (Organizational, People, Physical, Technological)
- Core principles: consent/choice, purpose limitation, data minimization, accuracy, transparency, accountability
- Integrated into ISO 27001 ISMS; assessed during certification audits via Statement of Applicability, no standalone certificate
Why Organizations Use It
CSPs use it for market differentiation, procurement acceleration, regulatory alignment (GDPR Article 28, HIPAA), risk reduction, cyber insurance benefits, and building stakeholder trust through transparent PII handling.
Implementation Overview
Start with gap analysis on existing ISMS, update policies/contracts/training, ensure subprocessors compliance. Applicable to CSPs all sizes/industries globally; requires third-party audits within annual ISO 27001 surveillance.
Key Differences
| Aspect | Australian Privacy Act | ISO 27018 |
|---|---|---|
| Scope | Personal info handling lifecycle, APPs, NDB scheme | PII protection in public clouds for processors |
| Industry | All sectors in Australia over $3M turnover | Cloud service providers globally |
| Nature | Mandatory Australian law with OAIC enforcement | Voluntary ISO code of practice |
| Testing | OAIC audits, investigations, assessments | ISO 27001 audits with 27018 controls |
| Penalties | Up to AUD 50M or 30% turnover fines | No legal penalties, certification loss |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about Australian Privacy Act and ISO 27018
Australian Privacy Act FAQ
ISO 27018 FAQ
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