Checklist · Privacy, Data Protection & Cyber

De-identification assessment record before a dataset is shared or released (Privacy Act s 6 definitions)

Record for deciding whether a dataset is de-identified (no longer about an identified or reasonably identifiable individual) before it is shared, sold, published or used to train a model: the data, the release environment, re-identification risks, controls and the decision.

Kind
Checklist. Steps or checks to work through and tick off.
Where it applies
Australia
AI use
Yellow AI can help in set ways. A lawyer checks specific points before use.
Law stated as at
18 October 2026
Status
Maintained. Checked on 18 October 2026 against the 2 authorities it cites, for Australia.
Version
1
Source
Written for this library

When to use it

Use before an organisation or agency shares a dataset with a partner, researcher or vendor, publishes open data, or uses data for analytics or AI training on the basis that it is not personal information. If the data is still personal information, the APPs apply to the use or disclosure.

Used for these tasks

Each task page says how far AI may help with the task and what the lawyer must review.

How AI may be used

AI may profile the dataset (fields, rarity of combinations, free text) and list re-identification risk indicators; the privacy officer and the lawyer decide whether individuals are reasonably identifiable in the intended release environment.

AI may

  • List fields and classify them as direct identifiers, quasi-identifiers, sensitive attributes or free text
  • Count small cells and unique combinations of quasi-identifiers and flag them
  • Draft the description of the release environment and controls from the data sharing agreement for checking

AI must not

  • Must not decide that the data is de-identified
  • Must not attempt to re-identify individuals or link the dataset with outside data except in a controlled test the privacy officer has approved
  • Must not be given the identified source data outside an approved environment

The lawyer checks

  • Direct identifiers are removed and quasi-identifiers, small cells and free text have been treated
  • The assessment considers who will receive the data, what other information they hold or can access, and the controls on them
  • The decision and its reasons are recorded, with a review date and a trigger for reassessment if the release environment changes
  • If individuals remain reasonably identifiable, the APPs (including APP 6 and, for overseas recipients, APP 8) have been applied to the disclosure

Method: how the Green, Yellow and Red levels are decided. This is guidance for planning, not legal advice.

Authorities

Read the full text

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