Allied Health NDIS Audit Checklist
PrivacyPrivacy Act: the Australian Privacy Principles and notifiable data breachesprivacy-act--app-6-use-and-disclosure
Requirement

APP 6: sharing client information with other practitioners and the NDIS

Health information collected to treat a client may be used or disclosed for another purpose only with consent or under an exception: a directly related purpose the client would reasonably expect, a requirement or authorisation under an Australian law (such as an NDIS reportable incident notice), or a permitted health or general situation.

Clause

Privacy Act APP 6.1 to APP 6.5

Regulator

Office of the Australian Information Commissioner

Edition held

Privacy Act 1988 (Cth), Compilation No. 104 (C2026C00227), in force 4 June 2026, registered 17 June 2026 (Schedule 1, the Australian Privacy Principles; Part IIIC, notifiable data breaches)

Checked current

6 October 2026, Federal Register of Legislation Versions API: the latest and current compilation on 6 October 2026

Who it applies to

Every allied health practice that provides a health service and holds health information, whatever its turnover (s 6D(4)(b)), every profession, speech pathology included, NDIS registered or not.

Under review, not in force

From 10 December 2026, APP 1.7 to 1.9 add automated-decision content to the privacy policy (Privacy and Other Legislation Amendment Act 2024, Schedule 1 items 87 and 88). Not in force yet.

APP 6.1Use or disclose personal information only for the primary purpose it was collected for,source
Requirement, our statement of the clause

Use or disclose personal information only for the primary purpose it was collected for, unless the person consents or an exception in APP 6.2 applies.

Evidence that typically shows this
  • A record of the purpose of collection and of each disclosure made, with its basis
Common gap to check
  • Reports sent to third parties with no recorded basis
APP 6.2(a)(i)For health and other sensitive information, a secondary use or disclosure withoutsource
Requirement, our statement of the clause

For health and other sensitive information, a secondary use or disclosure without consent needs a purpose directly related to the primary purpose that the person would reasonably expect, such as a report to the referring doctor or another treating practitioner in the client's care team.

Evidence that typically shows this
  • Client consent or a recorded reasonable-expectation basis for reports to referrers and care teams
Common gap to check
  • Information shared with schools, employers or family without consent or a recorded basis
APP 6.2(b)A use or disclosure required or authorised by or under an Australian law is permitted,source
Requirement, our statement of the clause

A use or disclosure required or authorised by or under an Australian law is permitted, for example notifying the NDIS Commission of a reportable incident under the NDIS incident rules, or a mandatory notification under the National Law.

Evidence that typically shows this
  • A list of disclosures the practice makes under a law, each with the law named
Common gap to check
  • Staff unsure which disclosures the law requires, delaying a notice
APP 6.2(c), (d)A use or disclosure is also permitted where a permitted general situation (s 16A, forsource
Requirement, our statement of the clause

A use or disclosure is also permitted where a permitted general situation (s 16A, for example lessening a serious threat to life, health or safety) or a permitted health situation (s 16B) exists.

Evidence that typically shows this
  • A procedure for disclosures in a serious threat situation, with who decides and how it is recorded
Common gap to check
  • No record kept of an urgent disclosure made to protect someone
APP 6.5Where information is used or disclosed because it is reasonably necessary for ansource
Requirement, our statement of the clause

Where information is used or disclosed because it is reasonably necessary for an enforcement related activity (APP 6.2(e)), make a written note of it.

Evidence that typically shows this
  • Written notes of any disclosure to an enforcement body
Common gap to check
  • Police requests answered with no written note
Worksheet: what your practice holds, and where
RefHeld (yes, partly, no, not applicable)Where it is keptOwnerLast reviewedNext review
APP 6.1
APP 6.2(a)(i)
APP 6.2(b)
APP 6.2(c), (d)
APP 6.5

Completing this worksheet records what your practice holds and where. It does not make a practice compliant or ready for audit, and it is not legal advice.

Related requirements

Privacy Act: the Australian Privacy Principles and notifiable data breaches

The same topic in other instruments (privacy and records)

See every requirement for your practiceSee the specimen practice