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Allied Health NDIS Audit Checklist: worksheet

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

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-9-government-identifiers/

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 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 regulations.
Source: https://www.legislation.gov.au/C2004A03712/latest/text
Practice software configured to use its own client numbersMedicare or NDIS numbers used as the client ID in files and file names☐ yes
☐ partly
☐ no
☐ n/a
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 applies.
Source: https://www.legislation.gov.au/C2004A03712/latest/text
A note of where identifiers are used (claims, NDIA requests) and the basisIdentifiers printed on documents that do not need them☐ 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.