Information Governance, Privacy and Personal Information

Personal information is at the heart of the PRIS Act, with ‘sensitive personal’ information being a subset of that.  Definitions of these terms from the PRIS Act are set out below.

Personal information

Information or an opinion, whether true or not, and whether recorded in a material form or not, that relates to an individual, whether living or dead, whose identity is apparent or can reasonably be ascertained from the information or opinion, and includes information of the following kinds:

• “…A name, date or birth or address
• A unique identifier, online identifier or pseudonym
• Contact information
• Information that relates to an individual’s location
• Technical or behavioural information in relation to an individual’s activities, preferences or identity
• Inferred information that relates to an individual, including predictions in relation to an individual’s behaviour or preferences and profiles generated from aggregated information
• Information that relates to 1 or more features specific to the physical, physiological, genetic, mental, behavioural, economic, cultural or social identity of an individual…”.

Sensitive personal information

Personal information that relates to an individual’s

• “…racial or ethnic origin;
• gender identity, in a case where the individual’s gender identity does not correspond with their designated sex at birth;
• sexual orientation or practices;
• political opinions;
• membership of a political association;
• religious beliefs or affiliations;
• philosophical beliefs;
• membership of a professional or trade association;
• membership of a trade union;
• criminal record; …
• health information;
• genetic or genomic information;
• biometric information; or
• any information of the kind above that can reasonably be inferred…”.

The PRIS Act requires the City of Perth to comply with 11 Information Privacy Principles.

IPP Exceptions

In some cases, the City of Perth is exempt from complying with the IPPs where  allowed by the PRIS Act. For example, the IPPs do not apply to information that is publicly available.

Some specific IPPs are also excepted if certain conditions are met.  For example, for any personal information it has collected that is necessary for its functions and activities the City of Perth is allowed to disclose the personal information to a law enforcement agency if it reasonably believes that the disclosure is necessary for a law enforcement function.

The City will sometimes seek to collect personal information from people, either because it has to (because the law requires it) or because it is necessary for one or more of the City’s functions or activities. Under the PRIS Act IPP 1.9, the City must take reasonable steps to ensure individuals are made aware of what personal information the City proposes to collect. This information is usually provided through a ‘collection notice’, including:

• How to contact the City of Perth regarding the notice or the collection of personal information
• How you may access the information (if applicable)
• The purposes for which the information is collected and will be used or disclosed
• Whether the City would usually disclose that information and, if so, to whom
• Any law that requires the particular information to be collected
• The main consequences (if any) if all or part of the information is not provided.

We aim to provide a collection notice at the time we collect your Personal Information. The City’s collection notices are also published on this website, noting that it may not always be practicable for some operations or functions for notices to be provided prior to collection.

The City does not require consent to collect personal information, although it does require consent for the collection of ‘sensitive personal information’.

If you choose to not provide to us your personal information, the City may not be able to provide some of its service or undertake all of its functions and activities (for example, the City will usually require personal information before it releases any grant funding).

Generally, the City is required only to collect personal information about an individual from that individual or with their consent, from another individual. Where that is not the case, the City is required to provide a collection notice to the individual whose personal information has been collected from another.

The City might be authorised to collect or disclose personal information under another written law.  For example, the Local Government Act 1995 authorises the Chief Executive Officer of the City to advise the Western Australian Electoral Commissioner of the need to prepare an electoral roll for City elections, and to receive a copy of that roll from the Commissioner.

The City’s functions and operations in part are set out in legislation and regulations with which the City is to comply, such as the following examples:

the Local Government Act 1995;

the City of Perth Act 2016;

the Privacy and Responsible Information Sharing Act 2024;

the Freedom of Information Act 1992 and State Records Act 2000;

the Building Act 2011;

the Bush Fires Act 1954;

the Cat Act 2011;

the Dog Act 1976;

the Food Act 2008;

the Gaming and Wagering Commission Act 1987;

the Graffiti Vandalism Act 2016;

the Liquor Control Act 1988;

the Metropolitan Redevelopment Authority Act 2011;

the Planning and Development Act 2005 and Planning Schemes, including the City of Perth Planning Scheme No. 2;

the Public Health Act 2016 and Health (Miscellaneous Provisions) Act 1911;

the Road Traffic Act 1974;

the Swan and Canning Rivers Management Act 2006;

authorisations and delegations given by the Western Australian government to Council, the CEO and other City employees including under the Environmental Protection Act 1986 for noise control, the Strata Titles Act 1985 and the Road Traffic (Vehicles) Act 2012; and

City of Perth Local Laws.

Section 8 of the City of Perth Act 2016 (WA) sets out objects of the City for the good government of persons in the city of Perth, including residents, ratepayers and visitors, to promote the continued growth and environmentally sustainable development of the city of Perth and to maintain and strengthen the local, national and international reputation of the Perth metropolitan area as an innovative, sustainable and vibrant global city that attracts and welcomes everyone.

The City is also responsible for a range of Local Laws including for activities on land, cats, dogs, fencing, health, outdoor dining, parking, public trading, thoroughfares and public places, and waste.

The City must also meet other obligations, such as federal and state legislation (for example collecting personal information for employment requirements), for authorised requests such as Court Orders and when required in accordance with contracts (for example releasing personal information for some procurement awards).

Where the collection or disclosure of personal information is required or authorised by law, the City’s collection notice will refer to that requirement.

The PRIS Act applies to contracted service providers (suppliers of goods and services to the City) when set out in the agreement between the parties. This is to appropriately protect personal information of the City’s residents, ratepayers, visitors and staff. The City has determined that all its suppliers should be bound to the PRIS Act, and has amended relevant terms and conditions to achieve this outcome. Suppliers or potential suppliers are welcome to contact the City’s Privacy Officer for further details.

Individuals have a right under the PRIS Act to request access to and correction of their personal information. Any requests received by the City for access or correction are, however, managed under the Freedom of Information Act 1992. No fees apply. It is suggested that individuals first contact the City’s Privacy Officer to enquire about this.

Your Choice / Your Request - Accessing and Correcting of Personal Information

When requested by an individual (or their authorised representative), subject to legal exceptions the City will:

• grant access to personal information; and/or
• progress requests to alter or correct personal information.

When giving access or progressing changes, the City will take steps:

• informally upon written request (when appropriate);
• in accordance with the PRIS Act (see IPP 6);
• in accordance with the FOI Act; and
• otherwise where agreed in writing or to meet legal requirements.

To make a request please contact the City’s Privacy Officer and support team by:

• Telephone: (+618) 9461 3333
• Email: [email protected]

Individuals may also request access to or correction of any personal information held by suppliers to the City. It is suggested that individuals first contact the City’s Privacy Officer to enquire about this.

Section 5.94 of the Local Government Act 1995 provides a list of certain local government information that a person can inspect, including any annual report, annual budget, register of gifts, proposed local laws, rate records or the register of owner and occupiers. Section 5.96 of the same Act allows a person to request a copy of any information for which they have a right of inspection, with additional requirements set out in the Local Government (Administration) Regulations 1996. However, section 76 of the PRIS Act requires the City to ensure that any personal information contained in a register is not disclosed unless it is satisfied that the information is to be used for a purpose relating to the register. The City does this by confirming that the information will not be used for another purpose (for example by statutory regulation or otherwise as set out in reg. 29B(b) of the Local Government (Administration) Regulations 1996.

The City maintains an extensive network of about 800 closed-circuit television cameras within the City’s boundaries. These cameras do not record sound, only images, and are used for purposes including protecting the safety of individuals, monitoring property and assets and, as set out in the City of Perth Act 2016, to provide a safe, clean and aesthetic environment for community members, city workers, visitors and tourists, whilst enhancing and protecting its natural environment. The City has placed signage throughout the City to notify individuals that they are within a location monitored by CCTV, and a full collection notice relating to CCTV usage is contained on this website.

Some City employees have body warn cameras that are activated during interactions with members of the public. Under the City’s procedures, employees authorised to use body worn cameras are required to advise individuals in the immediate vicinity that recording has been activated.

If an individual is captured either on City-operated CCTV or by a body warn camera, they can access that footage under the Freedom of Information Act 1992 (WA). It is suggested that individuals first contact the City’s Privacy Officer to enquire about this.

The PRIS Act allows individuals who are concerned that their privacy might have been interfered with – because the City has not complied with an Information Privacy Principle without lawful excuse – to complain to the City (in the first instance) and/or to the Office of the Information Commissioner Western Australia.

You may wish to raise concerns or lodge a complaint about privacy and information management. You may wish to raise concerns about different parts of the lifecycle of personal information management, including the City’s collection, use, storage and release of information.

You can take this step yourself or authorise another person to take steps on your behalf or on behalf of a group of people. You cannot raise concerns or lodge a complaint for another person unless you are authorised in writing or in accordance with legal requirements.

The City encourages informal resolution of privacy issues where appropriate. If you wish to raise a more formal complaint, this may include either one or more of the following:

1. an initial internal assessment by the City, including to consider whether the City has complied with its obligations;
2. an internal review by the City, based on a written request from you made within a reasonable time following the alleged issues and including relevant details – you might wish to use the complaints form of the Office of the Information Commissioner Western Australian to lodge your request;
3. a complaint (including about interference with privacy) to the Office of the Information Commissioner Western Australian, as set out in the PRIS Act and with additional details on their website;
4. a complaint to the Western Australian Office of the Ombudsman, noting this may also be referred to the Office of the Information Commissioner, as set out in the PRIS Act; and
5. (if applicable) a complaint to the Office of the Australian Information Commissioner, as set out in the Commonwealth Privacy Act 1988.

The City aims to acknowledge receipt of any internal review request within 5 working days and complete the review within 60 working days.

As outlined in the City’s Privacy and Personal Information Statement, any complaints – or queries – should be directed to the Privacy Officer at [email protected] or via telephone at Telephone: (+618) 9461 3333.

More details from the Office of the Information Commissioner Western Australia are available at How to make a privacy complaint.

From 1 January 2027, a ‘notifiable information breach’ occurs when unauthorised access to, or unauthorised disclosure of, personal information held by the City is likely to result in serious harm to any individual to whom the information relates. A notifiable information breach may also occur where personal information is lost, and serious harm is likely to result to any individual to whom the information relates.

Where the City suspects a breach has occurred, or where it is informed that a breach is likely to have occurred, it is required to immediately take all reasonable steps to contain the breach and mitigate any harm. Where the City has assessed that indeed a breach has occurred, and the harm threshold has been reached under the PRIS Act, it is required to notify the Office of the Information Commissioner and/or the Western Australian Chief Data Officer, and take reasonable steps to notify any individuals affected by the breach.

The City’s Privacy and Personal Information Statement (below) sets out, at a high level, how the City collects, uses, discloses, stores and protects personal information, and how you can exercise the rights you have under the Privacy and Responsible Information Sharing Act 2024 (WA) (PRIS Act). By publishing this Statement, the City is complying with Information Privacy Principle 5 (Openness and Transparency).

1. Overview

As the capital city of Western Australia, Perth is the business, government, transport, cultural and entertainment hub of the metropolitan area.  The City of Perth (the City) provides and supports a wide range of services, facilities and activities, including community centres, public places, environmental management, waste services, events, and regulatory and compliance functions.

Many of these activities rely on the responsible collection, use, storage, and disclosure of personal information.

This Privacy and Personal Information Statement sets out, at a high level, how the City collects, uses, discloses, stores, and protects personal information, and how you can exercise your privacy rights.

It is supported by the City’s Information Management Governance Framework and other internal policies, procedures and governance processes to demonstrate the City’s commitment to protecting information while enabling effective service delivery.

2. Our obligations

The City collects and uses personal information for services to the public and protects against the unauthorised use of, access to, and disclosure of that information.

The City is a Western Australian local government and a public sector entity for the purposes of the Privacy and Responsible Information Sharing Act 2024 (the PRIS Act).

Under the PRIS Act, the City follows the eleven Information Privacy Principles (IPPs) that govern how personal information is:

• collected;
• used and disclosed;
• stored and protected; and
• accessed and corrected.

Oversight of PRIS Act information protection and sharing and WA Freedom of Information Act 1992 requirements is provided by the Office of the Information Commissioner Western Australia.

The Office of the Australian Privacy Commissioner is the national regulator for Privacy Act 1988 (Cth) Schedule 2 and Commonwealth Freedom of Information Act 1982 requirements.

3. What is Personal Information?

Personal information is information or an opinion, whether true or not, whether recently recorded or not and whether recorded in a material form or not, about an individual, whether living or dead, whose identity is apparent or can reasonably be ascertained from the information or opinion.

Depending on the function or activity being provided, personal information collected may include:

• names and contact details;
• date of birth;
• residential or postal addresses;
• employment or business information;
• information about a person’s location;
• technical or behavioural information in relation to a person’s identity or their activities and preferences;
• account, reference or identifying numbers;
• unique identifiers, online identifiers and pseudonyms; and
• other information that infers or identifies, or could reasonably identify, an individual.

Some personal information is classified as Sensitive Personal Information. This includes information such as health information, racial or ethnic origin and other information that requires a higher level of protection. The City only collects sensitive personal information where consent has been given or where collection is required or authorised by law.

4. Why the City collects personal information

The City collects and uses personal information so it can effectively carry out its functions and activities for services to the Community, and as an employer and an outsourcing entity.

The extent of personal information collected by the City varies, depending on which City function or service you require.

If you choose to not provide or consent to the City’s collection, use or release of Personal Information, the City may not be able to complete all of the services it usually undertakes.  This may prevent you from being able to participate in some City arrangements, or to receive a City service.

The City’s functions and activities in part are set out in legislation and regulations with which the City is to comply, such as the Local Government Act 1995, the City of Perth Act 2016, the State Records Act 2000 and freedom of information legislation.

The functions and activities below broadly set out when the City will collect, use and disclose personal information:

• Council elections;
• arrangements for rate notices and payments;
• community services and activities, including at Citiplace, the Town Hall and the Library;
• responding to enquiries, complaints, and service requests;
• building and planning applications and approvals, and building preservation;
• health and safety requirements including inspections for clean food and retail premises;
• protection of the environment, parks and outdoor areas, including fauna and flora;
• protection of public spaces, such as dealing with graffiti and vandalism;
• safe use of public spaces including for community events;
• managing fines, permits, and licences;
• registration and facilities for domestic animals including cats and dogs;
• waste collection and recycling services;
• parking and related services;
• road and footpath maintenance and design;
• employment of staff and engagement of contractors; and
• authorisations and delegations given by the Western Australian government to Council, the CEO and other City employees, including under the Environmental Protection Act 1986 for noise control, the Strata Titles Act 1985, and the Road Traffic (Vehicles) Act 2012.

The City is also responsible for a range of Local Laws including for activities on land, cats, dogs, fencing, health, outdoor dining, parking, public trading, thoroughfares and public places, and waste.

5. How the City collects personal information

The City collects personal information when it is reasonably necessary to carry out its functions and services or to meet legal obligations.

Personal information may be collected:

• directly from individuals or their authorised representatives;
• from contracted service providers, including hosts of online apps and websites;
• from other government agencies or statutory authorities;
• from financial institutions for payment and verification purposes; and
• from publicly available sources where lawful.

The City collects personal information through a wide range of interactions, including:

• applications for services, approvals, permits and licences;
• complaints, service requests and enquiries;
• community consultations, surveys, and engagement activities;
• attendance at City‑managed facilities, programs, and events;
• employment, volunteer, and advisory group applications;
• procurement, tender and grant processes;
• correspondence, telephone calls, LiveChat, websites and social media;
• recordings, including footage from Closed Circuit Television (CCTV) and Body Worn Cameras (BWC); and
• access requests made under legislation, including Freedom of Information applications, court orders and subpoenas.

6. Collection Statement

The City will provide a collection notice to you at the time personal information is collected, explaining the purpose of collection and how the information will be used and disclosed.

All Collection Notices are also set out on the City’s webpage.

7. Use and disclosure of personal information

The City uses personal information primarily for the purpose for which it was collected, or for a directly related purpose authorised by law, taking into account what is fair and reasonable. This includes to:

• administer local government elections, rates, and property records;
• assess and manage applications, approvals, and registrations;
• issue notices, correspondence, and statutory communications;
• deliver community services, facilities, and programs;
• manage public spaces, infrastructure, and assets;
• conduct compliance, investigation, and enforcement activities;
• engage, employ, and manage staff, contractors, and volunteers; and
• meet legal, reporting and records management obligations.

Personal information may be also used or disclosed:

• with an individual’s consent;
• where authorised or required by law;
• as part of responsible information‑sharing arrangements with other government agencies; and
• in response to lawful requests, such as court orders or Freedom of Information applications.

Where appropriate and practicable, the City takes steps to limit, de‑identify or aggregate personal information before it is used for secondary purposes or disclosed.

The City may also share personal information between public sector agencies where lawful, proportionate and in the public interest.

8. Unique Identifiers

The City will only assign a unique identifier where it is necessary for the efficient performance of the City’s functions or activities.  Where unique identifiers are assigned, they will be managed in accordance with IPP 7 of the PRIS Act.

9. Automated processes

Some routine administrative activities rely on automated or system‑assisted processes, such as issuing rates notices, invoices, or reminders.

These processes operate under legislative authority with established controls and human oversight.  Enforcement or regulatory decisions are not made solely by automated means where this would not be lawful or appropriate.

10. Disclosure outside Australia

The City will only disclose personal information outside Australia where required for a contractual purpose, with your consent or authorised by law, as set out in IPP9 of the PRIS Act.

11. Storage and protection of personal information

The City takes reasonable steps to protect personal information from loss, unauthorised access, use or disclosure.

Measures include:

• physical, administrative, and technical security controls;
• access to personal information is restricted to elected members, staff, contractors and volunteers who have a legitimate requirement to access the information in the course of performing their role;
• secure record‑keeping and retention practices; and
• compliance with State record‑keeping requirements.

The City has controls in place and reviews its information management practices reflecting evolving operational, legal, and cyber security requirements.

12. Accessing and correction of personal information

The City takes reasonable steps to ensure the personal information we collect, and hold is accurate, up-to-date, and complete. This may include correcting personal information where it is appropriate to do so.

You may request access to personal information held by the City, or request corrections if information is inaccurate, incomplete, or out of date.

Requests can be made for example:

• informally, where appropriate;
• under the PRIS Act; and
• under the Freedom of Information Act 1992 (WA).

Some legal exceptions may apply.

To request access to your personal information please contact the City’s Enterprise Information Governance Team by:

• Telephone: (+618) 9461 3333
• Email: [email protected]
• Mail at City of Perth, Council House, 27 St George’s Terrace, Perth WA 6000

13. Privacy complaints and your review rights

The City aims to deal with privacy concerns fairly, promptly and in accordance with guidance issued by the WA Office of the Information Commissioner.

If you have a concern about how the City has handled personal information, you may lodge a PRIS Act privacy complaint as outlined below:

• raise the matter directly with the City’s Information Management Team for informal resolution;
• if informal resolution is not appropriate or successful, submit a written complaint outlining the details of the concern and the outcome sought;
• the City will assess the complaint and may undertake an internal review to determine whether privacy obligations have been met;
• you will be informed in writing of the outcome of the review and any actions taken, which may include remedial action or changes to processes; and
• if you are dissatisfied with the outcome, you may lodge a complaint with the Western Australian Information Commissioner.

Western Australian Office of the Information Commissioner

• Address: Albert Facey House, 469 Wellington Street, Perth WA 6000
• Telephone: (+618) 6551 7888
• Email: [email protected]

The Office of the Australian Information Commissioner may be contacted as follows:

• Address: 3/175 Pitt Street, Sydney NSW 2000
• Postal Address: GPO Box 5288, Sydney NSW 2001
• Telephone: 1300 363 992 or from outside Australia (+612) 9942 4099
• Enquiry form on the OAIC website.

The City aims to promptly acknowledge receipt of any review request and reply within 45 days.

14. Information breaches

In the event of an actual or suspected information breach, please refer to the City’s Information Breach Policy which sets out how the City prepares for, identifies and responds to information breaches, who to contact and what you can expect if your personal information is affected.

Collection Notice for City of Perth Meetings and Consent for Recorded Meetings

Meetings at the City of Perth are conducted for the primary purpose of enabling the City to perform its local government functions and activities including as set out in the Local Government Act 1995 and the City of Perth Act 2016.  Your information is managed, and may be disclosed within the City or externally, in accordance with the City’s Privacy and Personal Information Statement.

Please note that attendance at or participation in City of Perth meetings, virtually or in person, may result in the collection of personal information; depending on the method of participation this may include your name, image, voice, email address and times when joining and leaving.

Other than public Council and Committee meetings (for which legislative requirements are in place - see Council meetings | City of Perth), for public meetings or gatherings organised by the City, this collection will be for local government services and the various functions and activities of the City of Perth.  For meetings and operational gatherings to which you are invited, this collection is an inseparable part of your attendance at, or participation in, those meetings.

For any queries or concerns about personal information collection, use, storage or sharing please contact [email protected].

Additionally, meetings may be recorded and transcribed by the City of Perth.  Recordings and transcripts may be used for minute preparation, meeting documentation, training, service improvement and record keeping purposes and may be disclosed to attendees, absentees, relevant City personnel and other government agencies or contractors as authorised by law.

By accepting City email and other invitations and joining City meetings, unless you confirm otherwise you consent to the City recording audio, video, and any shared content (including chat messages, screen shares and documents) during and associated with the meeting.

If you do not consent to some or all being recorded, please notify the meeting organiser in advance of the meeting.