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Allied Health NDIS Audit Checklist: worksheet

APP 3: collecting health information, consent and necessity

Privacy Act: the Australian Privacy Principles and notifiable data breaches. 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 on 6 October 2026 (Federal Register of Legislation Versions API: the latest and current compilation on 6 October 2026).

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.

Standards library: https://compliance.theartofservice.com/frameworks/australian-privacy-principles-apps. Page: https://allied-health-ndis-audit-checklist.theartofservice.com/rules/privacy-act/app-3-collecting-health-information/

RefRequirement (our statement of the clause)Evidence an auditor or the regulator asks forCommon gap to checkHeld (yes, partly, no, not applicable)Where it is keptOwnerLast reviewedNext review
APP 3.2Collect personal information that is not sensitive only where it is reasonably necessary for one or more of the practice's functions or activities.
Source: https://www.legislation.gov.au/C2004A03712/latest/text
Intake and referral forms reviewed field by field for necessityIntake forms asking for information no service uses☐ yes
☐ partly
☐ no
☐ n/a
APP 3.3(a)Collect sensitive information, including health information, only with the person's consent and where it is reasonably necessary for the practice's functions or activities.
Source: https://www.legislation.gov.au/C2004A03712/latest/text
Consent recorded at intake for the health information collected, with how consent was given; Consent arrangements for children and people with a substitute decision-makerConsent assumed rather than recorded; No process where a parent, guardian or nominee consents☐ yes
☐ partly
☐ no
☐ n/a
APP 3.4(a), (c), s 16BSensitive information may be collected without consent only where an exception applies, such as collection required or authorised by an Australian law, or a permitted health situation under s 16B (for example where the information is necessary to provide a health service and is collected as required by law or in line with binding professional confidentiality rules).
Source: https://www.legislation.gov.au/C2004A03712/latest/text
A note of each situation where the practice collects health information without consent and the exception relied onCollecting a client's family history about other people without checking s 16B(1A)☐ yes
☐ partly
☐ no
☐ n/a
APP 3.5, 3.6Collect personal information only by lawful and fair means, and from the person unless it is unreasonable or impracticable to do so (for example a referral from a treating doctor).
Source: https://www.legislation.gov.au/C2004A03712/latest/text
Referral intake procedure noting when information comes from someone other than the clientNo record of the source when information comes from a third party☐ yes
☐ partly
☐ no
☐ n/a

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.