If I decide to use the Origins code to vary my message or offer (eg for web enquirers or callers to a call centre) am I in breach of the privacy legislation?

No.  Because Origins data appended to a customer record is not considered by the OAIC guidelines to be ‘sensitive information’, it is not subject to privacy legislation.

However, the bigger risk is reputational risk through poor marketing design or execution.  Organisations that design content, messages and deployment that is positive, creative and inoffensive to individuals are the winners.  It is important to remember that the Origins code is a probabilistic indicator of cultural background.

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