Australia · Privacy and data governance
Vinomofo determination puts temporary migration systems under APP 11
The Privacy Commissioner found an APP 11.1 breach involving a temporary cloud database used for a data migration. The determination is binding on the respondent and reviewable, not a general court precedent.
What this means
Understand the practical effect.
The Privacy Commissioner found an APP 11.1 breach involving a temporary cloud database used for a data migration. The determination is binding on the respondent and reviewable, not a general court precedent.
What to do
Turn the update into action.
Apply production-grade ownership, minimisation, configuration, logging, monitoring and verified deletion to temporary, migration and testing environments containing personal information.
Official source
Check the controlling material.
Practical support
Apply this update to your business.
Confirm the products, customer journeys, claims, suppliers or processes affected, then identify the evidence, ownership and timing needed for a defensible response.
Watchdog can assess the update against your circumstances and recommend the most useful next step.
Important information
Check the current position.
This update is general information, not legal advice. Laws, official guidance and proceedings can change. Check the current source and your specific facts before acting.
