APP 2 — anonymity + pseudonymity for individuals
Where reasonable, individuals must be able to deal with you anonymously or under a pseudonym.
Who must comply
All APP entities.
What triggers it
Engaging with individuals where identification not strictly required.
When due
Continuous.
Evidence required
Workflow analysis; consent + opt-out options; identifiers minimised.
Max penalty
Same penalty regime as broader Privacy Act breaches
Summary
APP 2 requires APP entities to provide individuals with the option of dealing anonymously or under a pseudonym, unless impracticable or required by law. Limits the default-required identification many businesses impose unnecessarily.
Enforced by
Source legislation
Topics
Related obligations
- CWLTHAPP 3 collection of sensitive informationAPP 3 bars collecting sensitive information — health, race, religion, sexual orientation and more — without consent. What counts as sensitive, the exceptions and penalties.
- CWLTHPublish a Privacy Policy compliant with APP 1Every APP entity needs a clearly-expressed Privacy Policy covering APP 1.4 requirements.
- CWLTHProvide an APP 5 collection notice at or before collectionAPP 5 requires notice of identity, purposes, recipients, consequences of not providing info, and where Privacy Policy lives.
- CWLTHAPP 8 cross-border disclosureBefore disclosing personal information overseas, APP 8 requires reasonable steps so the recipient meets the APPs — unless an exception applies. Steps and exceptions.
- CWLTHAPP 12 & APP 13 access and correction requestsIndividuals can ask to access (APP 12) and correct (APP 13) the personal information you hold — the strict response times, allowable refusals and how to comply.
- CWLTHAPP 7 direct marketingAPP 7 restricts using or disclosing personal information for direct marketing and requires a simple opt-out — when it applies, the exceptions and penalties.
Frequently asked questions
- Who must comply with APP 2 — anonymity + pseudonymity for individuals?
- All APP entities.
- What triggers APP 2 — anonymity + pseudonymity for individuals?
- Engaging with individuals where identification not strictly required.
- When is APP 2 — anonymity + pseudonymity for individuals due?
- Continuous.
- What is the maximum penalty for APP 2 — anonymity + pseudonymity for individuals?
- Same penalty regime as broader Privacy Act breaches
- What evidence is required for APP 2 — anonymity + pseudonymity for individuals?
- Workflow analysis; consent + opt-out options; identifiers minimised.
Source: https://oaic.gov.au/privacy/australian-privacy-principles/australian-privacy-principles-guidelines/chapter-2-app-2-anonymity-and-pseudonymity. Rules Mate is not a law firm. Always verify against the live regulator source before acting.