Allied Health NDIS Audit Checklist
PrivacyPrivacy Act: the Australian Privacy Principles and notifiable data breachesprivacy-act--app-9-government-identifiers
Requirement

APP 9: NDIS numbers, Medicare numbers and other government identifiers

A practice must not adopt a government related identifier (such as a Medicare number or an NDIS number) as its own client identifier, and may use or disclose one only where that is reasonably necessary to verify identity, to meet its obligations to an agency, or is required or authorised by law, or another listed exception applies.

Clause

Privacy Act APP 9.1, APP 9.2

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 9.1Do not adopt a government related identifier as the practice's own identifier for a client, unless required or authorised by law or prescribed by regulationssource
Requirement, our statement of the clause

Do not adopt a government related identifier as the practice's own identifier for a client, unless required or authorised by law or prescribed by regulations.

Evidence that typically shows this
  • Practice software configured to use its own client numbers
Common gap to check
  • Medicare or NDIS numbers used as the client ID in files and file names
APP 9.2Use or disclose a government related identifier only where reasonably necessary to verify identity for the practice's activities, to fulfil obligations to an agency or a State or Territory authority (for example claiming), where required or authorised by law, or another listed exception appliessource
Requirement, our statement of the clause

Use or disclose a government related identifier only where reasonably necessary to verify identity for the practice's activities, to fulfil obligations to an agency or a State or Territory authority (for example claiming), where required or authorised by law, or another listed exception applies.

Evidence that typically shows this
  • A note of where identifiers are used (claims, NDIA requests) and the basis
Common gap to check
  • Identifiers printed on documents that do not need them
Worksheet: what your practice holds, and where
RefHeld (yes, partly, no, not applicable)Where it is keptOwnerLast reviewedNext review
APP 9.1
APP 9.2

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