Privacy 108 Submission to Exposure Draft – Privacy Amendment

Privacy 108 has made a formal submission to the Exposure Draft of the Privacy Amendment (Personal Data Protection) Bill 2026, the next stage in the reform of Australia’s Privacy Act.

As a specialist privacy consultancy and law firm, we felt it was important to contribute our expertise to this consultation process and help shape the final legislation.

Our submission covers a range of issues raised by the Exposure Draft, and sets out our position on each of the key proposals.

You can read our full submission here.

Other Resources for the 2026 Privacy Reforms

We’ve been tracking the Privacy Act reform process closely, and have put together a range of resources to help you understand what’s changing and what it means for your organisation. Below you’ll find our other blog posts, webinars and guidance material on the 2026 reforms.

• Australia’s next wave of privacy reforms: unexpectedly bold but also timid – our take on the Exposure Draft as a whole, and where it goes further than expected and where it falls short.
• Privacy Act reform deep dive: APP 11, security and destruction, de-identification – a closer look at the proposed changes to APP 11 and what they mean for how organisations manage retention, destruction and de-identification.
• The next round of Privacy Act reform – what changes and how to prepare – our summary of the key changes across the Exposure Draft, why each one matters, and practical steps to start preparing now.
• Privacy 108 Webinar on the Privacy Reforms 2026: Consultation on Exposure Draft – Dr Jodie Siganto, Jonathan Gadir and Tom Mackie unpack six key areas of the 41 proposed changes, including the new definitions, the “fair and reasonable” test, the limited right of erasure and changes to direct marketing and online tracking rules.