Is my data compliant with privacy legislation after I append an Origins code to a customer record?

Yes.  The Origins code itself is not personal information.  And, when it becomes part of a record which is personal information, it is not considered to be ’sensitive information’.

This statement is based on legal advice, industry association advice, and the Australian Privacy Principles guidelines produced by the Australian Information Commissioner (see APP Guidelines issued by the OAIC, April 2015, Paragraph B139).  These principles are consistent across all Australian jurisdictions.

Of course, for research purposes, organisations may choose to de-identify a data-set containing Origins codes to derive rich insight into the cultural dimensions of consumer behaviour at population, or population sub-set level.  See also Coverage, Accuracy & Privacy.

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