Back to the requirement

Allied Health NDIS Audit Checklist: worksheet

APP 7: newsletters and marketing to clients

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-7-direct-marketing/

Applies when: APP 7 applies only to use or disclosure of personal information for direct marketing. On the profile it is not applicable until the practice answers yes. The question: Does the practice send newsletters, promotions or other direct marketing to clients or past clients?

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 7.1, 7.4Do not use or disclose personal information for direct marketing unless an exception applies; health information and other sensitive information may be used for direct marketing only with the person's consent.
Source: https://www.legislation.gov.au/C2004A03712/latest/text
Recorded consent for any marketing that draws on health informationMarketing lists built from treatment records without consent☐ yes
☐ partly
☐ no
☐ n/a
APP 7.2, 7.3Other personal information may be used for direct marketing where the person would reasonably expect it, or has consented (or consent is impracticable, for information collected from someone else), with a simple means to opt out, and (under 7.3) a prominent opt-out statement in each communication.
Source: https://www.legislation.gov.au/C2004A03712/latest/text
The opt-out mechanism in every marketing email or letterNo working unsubscribe or opt-out☐ yes
☐ partly
☐ no
☐ n/a
APP 7.6, 7.7On request, stop direct marketing, stop disclosing for others' marketing, and say where the information came from, free of charge and within a reasonable period.
Source: https://www.legislation.gov.au/C2004A03712/latest/text
A log of opt-out and source requests with the date actionedOpt-outs not applied across all mailing tools☐ yes
☐ partly
☐ no
☐ n/a
APP 7.8APP 7 does not apply to the extent the Spam Act 2003, the Do Not Call Register Act 2006 or another prescribed law applies.
Source: https://www.legislation.gov.au/C2004A03712/latest/text
A note of which law governs each marketing channel (email and SMS under the Spam Act)Email marketing run without considering the Spam Act☐ 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.