

The Office of the Australian Information Commissioner (OAIC) recently accepted an enforceable undertaking from Oxfam, related to a data breach in 2021. The OAIC’s investigation revealed a host of poor privacy practices at the non-profit, and there are important lessons for others operating in this sector from this breach and the enforceable undertaking.
On January 20, 2021, Oxfam Australia experienced a data breach where an unauthorized user accessed their User Acceptance Testing (UAT) database and accessed up to around 1.7 million records. This database contained personal information of Oxfam’s supporters, including names, addresses, dates of birth, donation history, and for a small number of individuals, financial details like account numbers and masked credit card information were also included. Oxfam had held much of the information for more than 7 years.
Oxfam became aware of the breach when they found records being advertised for sale on an online forum for stolen data (RaidForum). 14 sample records were published on the forum too, which Oxfam used to verify the breach. Following the discovery, Oxfam notified the Australian Information Commissioner (OAIC) and the affected individuals.
The OAIC launched an investigation into Oxfam’s data handling practices and raised concerns about a range of poor practices, including:
The OAIC also noted that in some cases over seven years for individuals who had not donated to or been contacted by Oxfam during that time and even for some who had made a Do Not Contact request of Oxfam. This highlights the relative lack of data disposal practices at Oxfam during this period.
Oxfam has agreed to an enforceable undertaking. This includes commitments to improve its security and operational procedures, such as:
We recommend that all non-profits adopt these privacy practices at a minimum if you collect and store any personal information from your supporters and stakeholders.
Oxfam also agreed to destroy or de-identify the personal information of individuals who haven’t engaged with them in over seven years, those with invalid engagement dates in their system, and those who requested no contact and haven’t engaged in seven years.
Additionally, Oxfam will review their testing processes, engage an independent expert to assess their compliance with the Privacy Act, and participate in a public engagement program with the OAIC about the incident.
In addition to the requirements outlined in the enforceable undertaking, Oxfam implemented further procedures to uplift its privacy practices, including:
The non-profit sector is attractive to cyber criminals and, with many being underfunded with overworked and undertrained teams, they can be somewhat of a soft target.
We have seen a number of high profile cyber attacks involving the non-profit sector in Australia, including:
The OAIC published a detailed guidance for non-profit organisations in 2024. The insights remain relevant today, and we strongly recommend reading the guidance as a starting point.
Next, consider the steps Oxfam took to improve its privacy and security posture. Has your non-profit got those same measures in place? If not, your next step is to review your practices and create a roadmap for improving your current practices.
In this regard, there’s a list from the Australian Signals Directorate that’s helpful:
You can find a downloadable version of this checklist here.
Finally, the OAIC really emphases in its guidance to non-profits that you cannot lose information you don’t hold. In other words, it’s crucial to focus on deleting or deidentifying data at adequate intervals.
And, as we said in our earlier coverage of the OAIC’s guidance for non-profits: Boiling it down, when it comes to protecting personal information, there are 3 key things to keep in mind:
Our team of privacy consultants regularly works with non-profits to bolster privacy and security practices. If your organisation needs help, feel free to reach out for an obligation-free consultation.
Or join our free 2 x monthly newsletter to stay on top of trends and training in Australian privacy:
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