Case Study: Privacy Impact Assessment for facial recognition technology
The background
Against the background of the recent Bunnings decision by the Administrative Review Tribunal, we have been assisting our client, a vertically integrated primary producer, with the preparation of a comprehensive Privacy Impact Assessment (PIA) in connection with its implementation of facial recognition technology (FRT) across multiple operational sites.
How we assisted
Given the backdrop of heightened regulatory focus on the use of FRT, key areas of focus for the PIA included information flows, consent management, data security, and data retention practices. Our PIA provided targeted, actionable recommendations to support the client’s privacy compliance. In doing so, the PIA provided a structured framework for the lawful deployment of FRT, minimising compliance risks while supporting operational objectives such as fraud prevention and adherence to industry specific regulatory requirements.