Privacy Policies for the AI Era: What Automated Decision-Making Transparency Actually Requires

If any tool in your business scores, screens, prices, or filters customers automatically, your privacy policy is about to need a new section.

New automated decision-making (ADM) transparency obligations under the Privacy Act take effect on 10 December 2026, and they catch far more businesses than most expect. The definition of "computer program" covers everything from a basic scoring spreadsheet to machine learning and generative AI, and there's no grandfathering: if it's running on the day the law commences, it's in scope. Sahil Bhandula, Senior Lawyer at Lawpath, walks through what counts as automated decision-making, the threshold test that triggers disclosure, and exactly what your privacy policy needs to say. Practical, not theoretical.

15th October, 2026, 12:00 PM AEDT

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In this session, Sahil will cover:

  • What actually counts as ADM: The broad definition of "computer program" under the new rules, and why rule-based tools and spreadsheets can qualify just as much as AI
  • The significant effect threshold: How to work out whether a decision your systems make or assist with is significant enough to trigger the disclosure obligation
  • What your policy must say: The three specific disclosures required, the personal information used, the decisions made solely by the program, and the decisions it substantially contributes to
  • No grandfathering, no grace period: Why existing systems are caught regardless of when they were built, and what that means for your audit timeline
  • What this doesn't require: Where the line sits between disclosure and a right to contest, and what real non-compliance risk looks like
 

Why Attend?

Get ahead of a deadline with no phase-in and a definition wider than you think.

Find out if you're already caught

Most businesses assume this is an "AI company" problem. If you score, prioritise, filter, or price using any automated tool, it's worth checking.

Get your audit started before the rush

With no grandfathering and a hard commencement date, businesses that leave this to November will be scrambling. This session gives you the checklist to start now.

Know exactly what to disclose, not just that you need to

The obligation is specific: three categories of information, spelled out in the legislation. Walk away knowing what to actually write.

Ask Sahil your specific questions live

Bring your platform, your tools, your current privacy policy. Sahil will work through what applies to your business directly.

 

 

Limited seats available, register today!

 

 

 

Note for accountants and lawyers: this session isn't CPD accredited and doesn't count towards your annual points or units.

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