Summary of recommendations to address systemic issues

45.31 As noted above, a major concern of stakeholders is the limited ability of the OPC to address systemic issues. The OPC requires a number of tools and strategies to enable it to discover, monitor and remedy systemic issues in agencies, organisations and industries. Ideally, these tools and strategies must allow the Privacy Commissioner to act proactively to identify and resolve systemic issues before a breach occurs and, when enforcing the Act, to act in a manner that deters the agency or organisation involved and acts as a general deterrent to other agencies and organisations.

45.32 The ALRC makes a number of recommendations throughout Part F that are aimed at increasing the OPC’s ability to monitor and remedy systemic issues. Taken as a whole, these recommendations would provide the OPC with an appropriate ‘toolkit’ to deal with systemic issues in privacy compliance.[23]

[23] See, eg, Recs 47–6, 49–5, 49–6, 50–1, 50–2.