Balance access with protection
AML records need usable access for authorised work and protection against unauthorised access. Plan retrieval and security together.
Sections 111 and 116 require English records, or records readily accessible and readily convertible into written English.
For personal information, APP 11 requires reasonable security steps. The OAIC explains that these include technical and organisational measures.
Sources: Federal Register of Legislation: 111(2) and 116(1); Office of the Australian Information Commissioner: Key points; sections B, I and J.
Map the actual storage locations
Identify the customer systems, folders, approved messages, supplier portals and paper files used for records.
A practical design identifies the main record, supporting material and authorised users. Assign responsibility for retrieval and recovery.
Examine what happens when an employee leaves or a supplier account closes. Do not rely on one person’s private credentials.
Sources: Federal Register of Legislation: 111(2) and 116(1); Office of the Australian Information Commissioner: Key points; sections B, I and J.
- Working record
Identify the authoritative customer record.
- Supporting material
Keep usable links to documents, decisions and related transactions.
- Access test
Examine retrieval when a staff member leaves or supplier access ends.
Can you recover the complete file?
Read this visual with the source conditions and explanation in this section.
Follow the process from top to bottom.
Invented example: the missing message thread
In a fictional case, a customer instruction is in an approved message channel. Staff cannot retrieve it after the employee leaves.
The business defines a process to preserve relevant instructions in the controlled record. The example does not require copying every conversation.
Sources: Federal Register of Legislation: 111(2) and 116(1); Office of the Australian Information Commissioner: Key points; sections B, I and J.
Test access and recovery
Use an authorised user to retrieve a sample record. Then examine whether a user without permission can access the same sensitive information.
Confirm that exported files remain readable and linked to the correct customer or transaction. Review permissions when responsibilities change.
These exercises support the record process. They do not establish compliance with every privacy or security duty.
Sources: Federal Register of Legislation: 111(2) and 116(1); Office of the Australian Information Commissioner: Key points; sections B, I and J.
Examine exports before exit
Before closing a supplier account, confirm that authorised staff can open the exported records and their supporting evidence.
Preserve identifiers and relevant dates. Record the retrieval result before removing the previous access route.
Sources: Federal Register of Legislation: 111(2) and 116(1); Office of the Australian Information Commissioner: Key points; sections B, I and J.