Submission to the OAIC on its Guide to Complaint Handling Procedures

Financial Rights made a submission to the Office of the Australian Information Commissioner on Consultation draft: Chapter 2 — Privacy complaint handling process.  The OAIC was seeking public comment on its draft Guide to privacy regulatory action (Guide).

This was a joint submission with the Consumer Action Law Centre and it addressed three overarching issues raised by the exposure draft:

• Complaints handling and enforcement are related but separate regulatory activities and should have separate regulatory actions.
• The Guide should have more explicit procedural timeframes.
• Issues of confidentiality of complaints in practice do not match the relevant statements in the Guide.

 We used our experience making a representative complaint under the Privacy Act to inform our comments.