Why Privacy Impact Assessments Matter

A Privacy Impact Assessment (PIA) is a systematic process for identifying and addressing privacy risks in projects, systems, or initiatives that involve personal information. It's not just a compliance checkbox — it's how you protect both your organisation and the people whose information you handle.

Catch problems early

Before they become breaches, complaints, or costly rework

Demonstrate due diligence

To regulators, boards, and the public

Build privacy into design

Rather than bolting it on at the end

Make informed decisions

About privacy trade-offs with documented rationale

The Office of the Australian Information Commissioner (OAIC) publishes a PIA framework that forms the basis for privacy assessment in Australia. PIMS implements this framework out of the box.

Who Needs to Conduct PIAs?

Different organisations have different obligations under Australian privacy law.

Mandatory

Australian Government Agencies

Under the Privacy (Australian Government Agencies — Governance) APP Code 2017, Commonwealth agencies must conduct a written PIA for all "high privacy risk" projects. This includes new data collections, system changes, and initiatives involving sensitive information.

Non-compliance can result in regulatory action by the OAIC.

Strongly Expected

Private Sector APP Entities

The OAIC strongly recommends PIAs for any private organisation covered by the Privacy Act (generally those with annual turnover above $3M). The 2024 Privacy Act reforms are expected to make PIAs mandatory for high-risk processing, similar to GDPR's DPIA requirements.

Best practice now, likely mandatory soon.

Special Category

Health Service Providers

Health service providers are covered by the Privacy Act regardless of size or turnover. There is no $3M threshold. This includes hospitals, medical practices, allied health, pharmacies, pathology, imaging, and anyone providing a health service.

Health information is "sensitive information" under the Act, attracting additional protections.

State/Territory

Public Health Services

State and territory health services (public hospitals, health departments) are covered by their respective state privacy legislation. Most states require or strongly recommend PIAs for new health information systems. Queensland Health, NSW Health, and Victorian DHHS all have PIA requirements.

Check your state's health privacy framework.

The Cost of Getting It Wrong

$50 Million

Maximum penalty for serious or repeated privacy breaches under the Privacy Act (as amended 2022)

Civil Penalties

Up to $50M for body corporates, $2.5M for individuals. OAIC now has expanded enforcement powers.

Notifiable Data Breaches

Mandatory notification to affected individuals and OAIC. Public disclosure damages reputation.

Reputational Damage

Loss of customer/patient trust. Media coverage. Long-term brand impact.

Operational Disruption

Incident response costs. System shutdowns. Remediation projects.

Legal Action

Class actions from affected individuals. Regulatory investigations.

Director Liability

Personal liability for directors who fail to ensure adequate privacy governance.

The Problem with Current Approaches

Most organisations manage PIAs using one of these methods. All have significant drawbacks.

The Word Document

The most common approach. Download a template, fill it in, save it to SharePoint.

  • No visibility for Privacy Officers
  • Can't track actions or risks
  • No workflow or approvals
  • No aggregate reporting
  • Version control nightmare

The Expensive Consultant

Hire external consultants to conduct PIAs. Great expertise, but...

  • $5-20K per assessment
  • Doesn't scale for volume
  • Knowledge walks out the door
  • Still delivers a Word document
  • No ongoing tracking

The Spreadsheet

Excel or Google Sheets for tracking. Better than nothing, but...

  • Manual data entry
  • No structured workflow
  • Limited access control
  • Disconnected from assessments
  • Data integrity issues

How PIMS Solves This

PIMS is purpose-built for Privacy Impact Assessments. Not adapted from a GRC platform. Not a document management system. Just PIAs, done right.

Start with OAIC Template

Use our OAIC-aligned template out of the box. Covers all 13 Australian Privacy Principles with conditional logic. Get started in minutes.

Configure Your Own

Clone the default template and customise it to your organisation's needs. Add sections, modify questions, define your risk framework.

Workflow Management

Draft → Submit → Review → Approve. Clear status tracking with role-based permissions.

Risk Management

Structured risk register with likelihood/consequence matrix. Link risks to compliance gaps and track treatment actions.

Audit Trail

Complete history of who did what and when. Demonstrate your privacy governance to auditors and regulators.

Reporting

Dashboard visibility for Privacy Officers. Export board-ready reports. Track your privacy posture over time.

Multi-Tenant

Manage PIAs across business units, projects, or clients. Enterprise SSO via Entra ID, or simple email login.

Sign-off Workflow

Role-based declarations and approvals. Responsible person, accountable person, and privacy officer sign-offs.

Who Uses PIMS?

PIMS is designed for organisations that need to manage privacy compliance at scale — without the enterprise price tag.

Healthcare

Hospitals, health services, medical practices, allied health

Aged Care

Residential aged care, home care, retirement living

Early Childhood

Childcare centres, early learning, family services

Government

Local councils, state agencies, statutory authorities

Not-for-Profits

Community services, disability services, charities

Consultancies

Privacy consultants, law firms, advisory practices

About Pragmatix

Pragmatix is a Brisbane-based consultancy specialising in digital health, privacy, and information governance. We've been helping healthcare and government organisations navigate privacy compliance for over 20 years. We built PIMS because we saw firsthand how much time is wasted on Word documents and spreadsheets.

Visit pragmatix.com.au

Ready to See PIMS in Action?

Book a demo to see how PIMS can streamline your privacy impact assessments and help you demonstrate compliance.

Frequently Asked Questions