Describe automated decisions in your privacy policy
This page lists the Diract features that decide something about a person, and the personal information each uses. You can adapt our text for your own privacy policy.
From 10 December 2026, Australian Privacy Principle 1.7 changes what a privacy policy must say. It covers a program an organisation has arranged "to make, or do a thing that is substantially and directly related to making, a decision". APP 1.7(b) covers a decision a person could reasonably expect to "significantly affect the rights or interests of an individual". The program must also use personal information about that individual.
APP 1.8 lists what the policy must then contain. Paragraph (a) asks for "the kinds of personal information used in the operation of such computer programs". Paragraph (b) asks for "the kinds of such decisions made solely by the operation of such computer programs". Paragraph (c) asks for the kinds of decisions where the program does "a thing, that is substantially and directly related to making the decision". A computer program includes a fixed set of rules, not only AI.
Turning on one of the features below means your business has arranged that program. Diract runs it, but your privacy policy is the one that has to describe it.
Two exemptions decide whether APP 1.7 reaches your business. The first is for a small business, defined in s 6D(1) of the Privacy Act 1988. Its "annual turnover for the previous financial year is $3,000,000 or less". The Australian Privacy Principles do not bind a small business unless s 6D(4) applies. That subsection catches a business that provides a health service and holds health information. It also catches one that discloses personal information "for a benefit, service or advantage".
The second is for employers. Section 7B(3) exempts an employer's act that is "directly related to" two things. The first is "a current or former employment relationship between the employer and the individual". The second is "an employee record held by the organisation and relating to the individual". It covers your employees and nobody else. A contractor's check ins and your clients' details are outside it.
On this page
List the features you use
Open Admin, then Kiosk accounts. Note whether you use Check in from the app and Geo Lock.
Open Admin, then Face ID, and note whether your staff use it.
Open Admin, then Calendar, and note whether you use Refuse a job that clashes.
Note whether you use Run Pay under Tables in the sidebar. Then check the Wage Compliance tab on a staff member's profile, and Auto Time Recording on the Time Entry dashboard.
Add a paragraph for each one to your privacy policy
Each feature you noted has a paragraph under Text you can adapt below. Copy the ones you use into the part of your privacy policy that covers decisions made by computer programs.
Change the words to match your business: who your staff and clients are, and who reviews what. Leave out a feature you do not use.
Check your policy whenever you add a feature
Turning on another feature from the list means your policy needs its paragraph too. The obligation applies to decisions made after 10 December 2026, including by a feature you turned on before then.
This page is general information, not legal advice. It is current as at 13 October 2026.
Text you can adapt
| Term | What it means |
|---|---|
| Check in with Geo Lock | When a staff member checks in from the app, our software compares their device's location at that moment with our office or the job's site. It refuses a check in made further away than the distance we set. It uses the person's location, and their jobs for the day where we book jobs. It does not track location at any other time. |
| Face ID | Staff who choose to enrol can check in at our kiosk by face. Our software compares a numeric description of the face at the kiosk with those of enrolled staff. It identifies the person only when the match is close enough. Otherwise it does not recognise them, and they use their PIN instead. The description is biometric information. No photograph is kept. |
| Run Pay and payroll | Our payroll software works out the tax withheld, superannuation and leave for each employee. It uses their tax file number declaration, pay details, hours worked and service dates. A person in our business reviews and finalises every pay run. |
| Wage Compliance | Our software compares each staff member's pay with the minimum rate for their award classification, or the national minimum wage, and shows whether it passes. It uses their role, pay basis, salary and classification. A person in our business decides what to pay. |
| Refuse a job that clashes | Our calendar refuses to book a staff member for a job that overlaps their other jobs or shifts, counting the drive between them. It uses their bookings and the job addresses. |
| Auto Time Recording | Our software drafts time entries from completed tasks and from the emails filed to a matter. It suggests the staff member who did the work for each one. It reads the client's matter, the emails and the staff member's work. A person in our business reviews each draft before it is saved, and it affects the client's bill only once saved. |