Australian Privacy #2: Cross-Border Disclosures

How Australia regulates cross-border disclosures under APP 8 — and how to manage GDPR-shaped expectations in practice.

Cross-border data flows engage multiple privacy regimes simultaneously. Cloud hosting. SaaS platforms. Offshore support desks. Global vendors. Many Australian organisations underestimate where “disclosure” actually occurs — and over-assume that GDPR logic governs the conversation.

In Australian law, cross-border data transfers are regulated primarily through APP 8, supported by accountability provisions and the notifiable data breach scheme. The structure is not built on a controller/processor architecture. Instead, it relies on a different allocation of responsibility.

This TalkAbout examines:

• What constitutes a “disclosure” under Australian privacy law
• When APP 8 is triggered — and when it is not
• The accountability model embedded in the APP framework
• How Australian cross-border rules differ structurally from GDPR transfer mechanisms
• Common compliance missteps in vendor contracting
• How multiple regimes can apply simultaneously

We move beyond abstract doctrine and focus on operational decision points: procurement, outsourcing, cloud architecture, and group structures.

Why Attend?

If you advise on privacy, procurement, operations, or governance, cross-border issues are unavoidable.

This session will help you:

• Correctly identify where disclosures occur in practice
• Distinguish “use,” “disclosure,” and offshore access scenarios
• Understand the risk allocation model in APP 8
• Navigate GDPR-shaped contractual demands with clarity
• Strengthen your organisation’s compliance posture without importing structural assumptions that do not apply

The goal is conceptual precision that supports defensible operational decisions.

Who This Is For

• Privacy specialists
• Compliance and risk managers
• In-house counsel
• Procurement and vendor governance professionals
• Consultants advising Australian entities with offshore exposure

Participants should have working familiarity with the APP framework.

Format

Online (live session)

WorkAccord Privacy TalkAbouts are structured, practitioner-level discussions.

Expect:

• A concise doctrinal framing
• Analysis of structural differences (APP vs GDPR)
• Applied governance scenarios
• Space for practical questions