A new transparency obligation commences under the Privacy Act on 10 December. If your agency uses anything that scores leads, estimates prices, or decides who gets contacted first — this applies to you. Most agencies don't know it's coming.
From 10 December 2026, organisations using computer programs to make — or materially assist in making — decisions that significantly affect people must disclose it in their privacy policy. Plainly. Including what information those systems use.
The drafting is broad on purpose. It captures AI tools, rule-based systems and automated assessment technologies alike. You don't have to be "using AI" in any dramatic sense to be caught by it.
Most agencies use at least two. Most would struggle to explain how any of them reached a particular outcome.
In January 2026 the OAIC ran its first-ever proactive privacy compliance sweep — around 60 organisations across six sectors, chosen because they collect personal information face to face.
Penalties have been reported up to $66,000. But the money isn't the significant part. The significant part is that the regulator is no longer only responding to complaints after something goes wrong. An agency can come under scrutiny with nothing having gone wrong at all.
I'm a licensed agent, still listing and selling. I've spent the last six months building software to take the admin out of running a campaign — the appraisal, the copy, the vendor reports, the settlement chain.
Somewhere in that, I built something I didn't expect to matter this much.
An actual output. It refuses to produce the document.
I built that because I didn't want to accidentally underquote. It turns out that being able to show why a system reached a conclusion is about to be a legal requirement, not a preference.
I'm writing a plain-English guide: what counts, what doesn't, and nine questions to work out whether your agency is actually ready. No charge, whether you ever use anything I've built or not.
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