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wiki:contents:fatca:aus_fatca_implementation [2019/02/14 07:20] – [Resources:] carl | wiki:contents:fatca:aus_fatca_implementation [2019/02/14 07:29] – [Parlimentary Review & Legislation] carl |
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=== Privacy Considerations === | === Privacy Considerations === |
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FIXME No Privacy Impact assessment was done on the FATCA implementing legislation even though recommended by the Privacy Commissioner, Office of the Australian Information Commissioner (OAIC) - Item 26 of [[https://www.oaic.gov.au/engage-with-us/submissions/intergovernmental-agreement-to-implement-fatca|OAIC Submission to Treasury on Intergovernmental agreement to implement FATCA]] | FIXME No Privacy Impact Assessment (PIA) was done on the FATCA implementing legislation even though recommended by the Privacy Commissioner, Office of the Australian Information Commissioner (OAIC) - Item 26 of [[https://www.oaic.gov.au/engage-with-us/submissions/intergovernmental-agreement-to-implement-fatca|OAIC Submission to Treasury on Intergovernmental agreement to implement FATCA]]. Correspondence with Treasury as part of an unsuccessful FOI request, clarified that OAIC’s submission only suggested that Treasury complete a PIA on FATCA meaning there was therefore no legal requirement for Treasury to do-so. However, the privacy implications and the OAIC’s submission were subsequently discussed in the [[http://ris.pmc.gov.au/sites/default/files/posts/2014/05/08_RIS_accessible.pdf|Regulation Impact Statement]] prepared by Treasury. |
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When looking at Privacy impact of FATCA, we should also be looking at CRS as similar privacy concerns exist. The [[https://www.ato.gov.au/law/view/document?DocNum=0000080940&PiT=20160331000000&FullDocument=true|Explanatory Memorandum]] includes a section on Human Rights which talks about privacy, but nothing from the Privacy Commissioner. | When looking at Privacy impact of FATCA, we should also be looking at CRS as similar privacy concerns exist. The [[https://www.ato.gov.au/law/view/document?DocNum=0000080940&PiT=20160331000000&FullDocument=true|Explanatory Memorandum]] includes a section on Human Rights which talks about privacy, but nothing from the Privacy Commissioner. |