The Privacy Commissioner, Karen Curtis, has recommended a range of privacy safeguards be developed for the proposed health and social services
access card. These recommendations have been made in her submission to
the first Discussion Paper released by the Access Card Consumer and
Privacy Taskforce.

In her submission to the Taskforce, Ms Curtis proposes that a number of key areas be addressed in the access card planning process including in the areas of card system design, technology choices, legislation and oversight measures.

The submission also calls for the enactment of legislation with privacy protection measures which apply over all elements of the access card system, including sanctions and remedies. Specifically, it recommends that legislation: limit the uses of the physical card; prevent unauthorised access to, collection or misuse of information on the card or chip; and prevent unauthorised or unintended
uses and disclosures, including routine data-matching. In addition, the submission suggests that individuals should have transparent rights to access and, where necessary, correct information on the system.

The submission suggests that further detailed privacy impact assessments be undertaken during the design and implementation of the access card system.