From: "Nigel Waters" <nigelwaters@iprimus.com.au>
To: <Criminal.Law@ag.gov.au>
Cc: "andrew Solomon" <andrewsolomon@privacy.gov.au>,
	"APF Board" <APFBoard@privacy.org.au>
Subject: Draft Model Spent Convictions Bill
Date: Sun, 8 Feb 2009 15:33:39 +1100

To: Ms Sarah Chidgey
Assistant Secretary
Criminal Law Branch
Attorney-General's Department
 
The Australian Privacy Foundation would like to make a submission in support of the concerns raised by the Australian Privacy Commissioner (OPC) in her submission to the Department on the Draft Model Spent Convictions Bill.
 
Unfortunately, as an all volunteer organisation, currently facing a number of consultations, we have not been able to resource an independent submission on this draft Model Bill. However, we are satisfied that the OPC has identified some significant privacy threats in the draft Model Bill.  We support the Commissioner's suggestions for amendments to provide greater privacy protection. We also support her other proposals, as well as her question about the policy reasons for limiting the definition of an 'eligible adult offence' to those with a sentence of less than 12 months, which would seem to represent a major weakening of current Commonwealth spent conviction scheme, which has a threshold of 30 months.
 
Thank you
 
Nigel Waters, Board Member
Australian Privacy Foundation
GPO Box 1196 Sydney 2000
Phone: 02 4981 0828 and 0407 230342
E-mail: Board5@privacy.org.au
APF website: http://www.privacy.org.au/