Australian enterprises are facing a fundamental shift in how they handle personal information.
Consumer data rights reforms are introducing comprehensive operational, legal, and technical responsibilities that extend across every aspect of business operations: from initial data collection to storage, internal team sharing, and external system integration.
John Harding, general manager of managed services at Konica Minolta Australia, emphasises the critical nature of this shift: “Organisations should treat data like any other regulated asset. Every time personal information enters a system, it must come with clear context: how it was collected; what purpose it serves; where it sits; and who has access. This level of visibility keeps data use consistent across departments and platforms. Businesses will struggle to meet even the most basic compliance requirements without it.”
Understanding data governance in the context of consumer rights
Think of your business data as a treasure chest without proper management, it’s easy for it to be lost, damaged, or stolen. Data governance is like a treasure map, ensuring your data is safe, accurate, and used to its fullest potential. This means knowing who’s responsible for what, like having the finance manager oversee financial data, ensuring consistency across your systems (e.g., customer names are always spelled correctly), and protecting sensitive data by controlling access.
Beyond organisation, good governance helps you comply with evolving consumer data rights laws, safeguarding customer privacy and avoiding costly fines or security breaches. In essence, data governance treats your data as a valuable asset by setting clear policies, assigning roles, and adhering to legal requirements, your business can make smarter decisions, build trust, and run more efficiently.
Key elements of modern data governance
- Policies: Establishing clear guidelines for data use and protection that align with consumer data rights requirements.
- Roles & Responsibilities: Defining who manages and uses data at every level of the organization.
- Legal Compliance: Adhering to laws like the Privacy Act, Government Information (Public Access) Act, and emerging consumer data rights legislation.
- Operational Transparency: Ensuring every piece of personal information comes with clear context about its collection, purpose, location, and access permissions.
The challenge of access and deletion requests
One of the most immediate impacts of consumer data rights reforms is the requirement to handle access and deletion requests quickly and accurately. These requests often reveal where business systems fall short, requiring organizations to retrieve every piece of data linked to a customer across all platforms and formats. The scope of these requests is comprehensive, including traditional documents, forms, emails, drop files, and even hand-written information. Manual workarounds or disconnected systems create significant challenges, slowing response times and increasing the risk of missing critical information.
Businesses must be able to locate and compile customer data from multiple sources instantly. This requirement exposes the weaknesses of fragmented data storage systems and highlights the need for integrated data management approaches that can track information across all touchpoints. As privacy laws evolve, SMEs must carefully manage not just personal data but also metadata, which includes timestamps, location data, and call logs. Although metadata may not always be personally identifiable, it can still raise privacy concerns and face legal scrutiny.
The recent case of Grubb vs Telstra in the Federal Court of Australia highlighted the complexities of metadata classification. While the court ultimately ruled that metadata is not considered personal information under the Privacy Act 2003, the case demonstrates the evolving nature of data privacy interpretation and the need for businesses to stay current with legal developments. To navigate this evolving landscape, SMEs should understand the difference between personal data and metadata, ensure compliance with privacy laws like the Privacy Act 2003 and GDPR, implement strong data protection measures, obtain clear consent for data collection, be prepared to handle metadata requests, and stay updated on legal changes.
John Harding emphasizes the importance of matching access control to user responsibilities: “Access control must match the responsibilities of each user. For example, a team member managing service requests may need access to a customer’s email address, though not their payment history or full contact records. Granting broader access than required increases risk and makes it harder to track down issues when they occur. Role-based permissions limit exposure while keeping daily tasks efficient. Regular reviews maintain alignment with how people work across systems.”
This approach ensures that employees have access to the information they need to perform their roles effectively while minimizing exposure to sensitive data that isn’t relevant to their responsibilities. Retention policies are under increasing pressure from consumer data rights reforms. Holding onto data after it’s no longer required increases both risk and storage costs.
Businesses need systems that can identify stale data, apply expiration rules, and act on withdrawal of consent. Each of these steps must connect across systems to ensure the business doesn’t miss a copy sitting in a shared drive or old archive. This comprehensive approach to data lifecycle management is essential for compliance and operational efficiency.
The challenge extends beyond internal systems to third-party platforms. Businesses remain responsible for customer data even when it flows through a vendor’s system. Contract terms are only part of the solution—regular reviews of how vendors manage access, store information, and apply audit controls are critical. Asking for evidence of these controls and maintaining ongoing oversight of third-party data handling practices is essential for reducing risk and maintaining compliance.
Read our 5-step implementation guide for SME data governance
Essential tools for SME data governance and consumer rights compliance
Based on the comprehensive requirements outlined above, SMEs should consider implementing tools that address multiple aspects of data governance and consumer rights compliance:
Document and content management solutions
- Integrated document management systems that can track and categorise all forms of customer information
- Content lifecycle management tools for automated retention and deletion
- Search and discovery platforms capable of locating personal information across multiple formats
Access control and security platforms
- Role-based access management systems that align with job functions and data sensitivity
- Identity and access management (IAM) solutions for comprehensive user authentication and authorisation
- Data loss prevention (DLP) tools to monitor and control data movement
Compliance and audit systems
- Automated compliance monitoring platforms that track adherence to consumer data rights requirements
- Audit trail systems that maintain comprehensive logs of data access and modifications
- Request management tools specifically designed for handling consumer access and deletion requests
Data integration and quality management
- Master data management (MDM) systems that create single sources of truth for customer information
- Data quality tools that ensure consistency and accuracy across all systems
- Integration platforms that connect disparate systems for comprehensive data governance
Training and awareness solutions
- Learning management systems (LMS) for delivering role-specific data governance training
- Policy management platforms that ensure current procedures are accessible to all staff
- Awareness and testing tools that reinforce proper data handling practices
Consumer data rights will continue expanding, representing a permanent shift in how personal information is treated across Australian enterprises. Businesses that act now, with practical and coordinated changes, will reduce complexity and build more trust in how they work. The integration of robust data governance practices with consumer rights compliance isn’t just about meeting legal requirements—it’s about building sustainable business practices that support growth, innovation, and customer trust in an increasingly data-driven economy. Success requires viewing data governance not as a compliance burden but as a strategic advantage that enables better decision-making, improved customer relationships, and reduced operational risk. Organizations that embrace this perspective will be better positioned to thrive in Australia’s evolving regulatory landscape while building the foundation for long-term business success.
Read NSW Data Governance Toolkit here
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