The new transparency obligation, and what it means in practice
From 10 December 2026, new privacy policy requirements apply to automated decisions. If you’ve arranged for a computer program to make, or substantially and directly inform, decisions that significantly affect an individual’s rights or interests using their personal information, you’ll need to include more information in your privacy policy.
This IAB Australia policy briefing explains what the obligation means for your business. It shows that the rules reach well beyond AI, covering rule based processes, machine learning, software and apps, and generative AI tools such as chatbots. It explains what “arranging for” a program includes, from in house software and third party tools to customised off the shelf products and AI agents. It also sets out when a decision counts as significant, using practical examples such as programmatic advertising for significant goods or services, personalised pricing, and recruitment software. Finally, it covers what your disclosure should include, and notes that software providers should give their clients clear information so those clients can update their own privacy policies.
Why it’s useful: Programmatic and personalised advertising are caught where significant goods or services are being sold. That means this change directly affects the digital advertising industry. The briefing turns the OAIC’s high level guidance into practical examples and “worth knowing” notes, so you can work out whether the obligation applies to you and get ready before 10 December.
