Scotts CA Logo

News

What Are the Privacy Policy Requirements for Australian E-Commerce Businesses?

An online store collects personal information constantly, and most of it arrives without anyone deciding to collect it.

 

An online store collects personal information constantly, and most of it arrives without anyone deciding to collect it. A visitor loads a page, and an analytics tag records an address. A customer abandons a cart and an advertising pixel follows them. Australian privacy law asks you to be transparent about all of it, in two documents: a short notice wherever you collect, and a policy that explains the whole picture. The hard part is not writing them. It is keeping them true, because every new tool changes what you collect, and most businesses write the policy once and leave it. A new obligation lands in December that makes accuracy harder to fake. This article explains which privacy obligations apply to an Australian e-commerce business, the two documents you need, what each must contain, and when to update them.

Who Needs to Comply

The Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) apply to your business if you have an annual turnover above $3 million. You may also need to comply if your business trades in personal information or provides a health service and holds health information.

If your turnover is below $3 million, the APPs may not legally apply to you. However, following them is best practice. Building compliant privacy practices early means you are ready as your business scales, and many payment processors and business partners will expect compliance.

Documents You Need

You will need two key documents:

  • a privacy collection notice: a short notice that appears at every point where you collect personal information; and
  • a privacy policy: a publicly available document on your website that explains how your business collects, uses, stores, and shares personal information.

Where You Must Display Collection Notices

You must display a collection notice at every point where you collect personal information, including:

  • newsletter or mailing list subscription forms;
  • account sign-up forms; and
  • contact and enquiry forms.

Each notice will briefly explain:

  • what information you are collecting;
  • why you are collecting it;
  • who you may share it with; and
  • where you store it.

Each notice must also link to your full privacy policy.

What Your Privacy Policy Needs To Cover

Your privacy policy must be written in plain language and easy to find on your website. For an ecommerce business, it will cover:

  • what you collect: such as contact details, payment information, IP addresses, and cookies;
  • how you collect it: such as directly from customers or through third-party payment processors;
  • why you collect it: such as to process orders, send marketing emails, or meet legal obligations;
  • who you share it with: including any third-party service providers that may store personal information outside of Australia;
  • cookies and tracking technologies: what you use, why you use them, and how customers can manage their preferences; you must specifically disclose tools such as Google Analytics or Meta Pixel;
  • AI tools: whether you use any AI tools to process personal information and how you maintain human oversight;
  • customer rights: including the right to access their personal information, request corrections, and opt out of marketing; and
  • your complaints process: including how customers can escalate a complaint to the Office of the Australian Information Commissioner (OAIC).

“Most of the businesses I speak to think their privacy policy is fine because nobody has complained about it, but that only tells you nobody has read it closely yet. The December changes are less about writing new paragraphs and more about actually knowing what your own tools do, which is often the harder question for a business to answer. I would rather spend an hour auditing your tools with you now than explain to the regulator later why the policy did not mention one of them.”

Danielle Henry

Lawyer, LegalVision

Keeping Your Documents Current

Review your privacy documents at least once a year. You should also update them whenever you:

  • add a new tool or technology that affects how you collect or use personal information;
  • change service providers; and
  • expand into new markets.

If you sell to customers in the EU or UK, additional obligations apply under the GDPR. These include identifying legal bases for processing personal information, setting data retention periods, and providing additional individual rights beyond those required under Australian law.

Key Takeaways

E-commerce businesses must understand their privacy obligations and keep their documents accurate as their data practices change. The key points are:

  • the APPs apply to businesses with an annual turnover above $3 million, but all e-commerce businesses should follow them as best practice;
  • you need both a privacy collection notice and a privacy policy;
  • collection notices must appear on subscription forms, account sign-up forms, and enquiry forms, and should link to your full privacy policy;
  • your privacy policy will cover what you collect, why, and who you share it with;
  • review and update your privacy documents annually and whenever your business practices change; and
  • selling to EU or UK customers triggers additional obligations under the GDPR.

 

 

 

By: Danielle Henry | 21 September 2026 | legalvision.com.au

Hot Issues

David Scott

David Scott

Partner

Chartered Accountant, Bachelor of Business (Accounting), Diploma of Financial Planning

David began his professional career in 1978 before returning to Geelong and establishing his own practice in 1987. Over nearly four decades, the firm has continued to grow and evolve into what is now Scotts Chartered Accountants.

David works closely with business owners and SMSF clients, bringing extensive experience across tax, business and superannuation matters. He has always believed in staying ahead of change, continuing to improve and making sure clients have the information they need to make confident decisions. His long held belief that “knowledge is power” continues to shape the way he works with clients and the wider Scotts team.

David is passionate about building a strong team and helping business owners look beyond the numbers, with a focus on understanding their business, identifying opportunities and planning for the future.

Outside of work, David is an avid runner and adventure traveller. He has completed multiple half and full marathons, including a marathon on all seven continents, along with challenges such as Everest Base Camp, Mount Kilimanjaro, the Kokoda Trail and the Marathon des Sables.

Larry Caravallo

Larry Cavallo

Partner

Chartered Accountant, Bachelor of Accounting and Bachelor of Commerce

Larry is passionate about helping clients grow their businesses through practical advice and strong, long term relationships. He takes the time to understand what clients want to achieve and enjoys working alongside them as their business grows and changes.

Larry believes accounting should be clear and easy to understand, with a focus on giving clients useful information and advice they can act on.

Outside of work, Larry enjoys gardening and playing golf.

Jessica Markewicz

Jessica Markewicz

Partner

Chartered Accountant, Bachelor of Commerce, majoring in Accounting and Financial Planning

Jess has over 20 years of experience working closely with businesses to help them achieve their financial and strategic goals. She works with clients across taxation, business planning, compliance and growth, with a focus on practical advice and building long term relationships based on trust and personalised service.

Jess has a strong interest in property and business development and is passionate about helping clients make informed decisions that support their long term success.

Outside of work, Jess loves travelling and making memories with her family, whether exploring new destinations or enjoying adventures closer to home.

Chris Scott

Chris Scott

Partner

Chartered Accountant, Bachelor of Commerce, majoring in Accounting and Management

Chris works predominantly with business clients, helping them navigate challenges, identify opportunities and work towards their long term goals. He enjoys working with a diverse range of businesses and developing practical solutions that reflect each client’s individual circumstances.

Outside of work, Chris is the Treasurer and an active player at Thomson Football & Netball Club, where he is passionate about supporting community sport. He also enjoys spending time with his wife Lauren, their two children, Jasper and Juke, and their dog, Leo.

Thomas Scott

Thomas Scott

Senior Client Manager

Chartered Accountant, Bachelor of Commerce, majoring in Accounting and Management

Tom works closely with business owners and family groups to help them understand their position and make confident decisions.

His approach is practical and personal. He focuses on making the numbers clear, explaining what matters and helping clients plan ahead, rather than just looking at things after the fact.

What drives Tom is helping clients build a business that supports the life they want and being someone they can rely on along the way.

Outside of work, Tom enjoys spending time with family and friends, watching sport and being a long suffering North Melbourne supporter.

Connor Jervies

Connor Jervies

Senior Client Manager

Chartered Accountant, Bachelor of Commerce, majoring in Accounting and Finance

Connor works closely with business owners across accounting, tax and business advisory. He enjoys helping clients understand their numbers, improve profitability and build stronger businesses through clear and practical advice.

Connor has a particular interest in working with growing businesses and helping clients plan ahead and make decisions that support their long term success.

Outside of work, Connor is passionate about local football and enjoys playing, coaching and contributing to his community club.

Hamish Irvin

Hamish Irvin

Accountant

Commerce graduate, majoring in Accounting, currently completing his final year of Chartered Accountant studies

Hamish has been part of the Scotts team for three years and works closely with the senior client managers, particularly Tom, across a range of client work. He enjoys building relationships with clients and is focused on continuing to develop his experience while growing his own client base.

Outside of work, Hamish is the ultimate sports tragic and will watch or play just about anything. He also umpires football on weekends, which keeps him active and involved in the game despite, in his words, having little footballing ability.

Hugh Menzies

Hugh Menzies

Accountant

Bachelor of Commerce, majoring in Financial Planning and Accounting

Hugh works with small business clients across a range of accounting and tax matters, including individual and business tax returns, financial statements and Business Activity Statements. He enjoys working with clients to help them understand their position and support them as they build their businesses and work towards their goals.

Outside of work, Hugh is a keen sports fan and enjoys spending time with family and friends.

Hugh Menzies

Iggy Roberts

Accountant

Bachelor of Business Accounting

Iggy works across a range of accounting and tax work, with a focus on preparing financial statements and supporting clients with their tax compliance obligations. He enjoys working as part of the wider Scotts team and helping ensure client work is completed accurately and efficiently.

Outside of work, Iggy enjoys staying active, catching up with mates and keeping up with the footy.

Hugh Menzies

Liam Purtill

Junior Accountant

Currently studying a Bachelor of Commerce at Deakin University

Liam works across a range of accounting and tax work, including preparing financial statements, Business Activity Statements and tax returns for businesses and individuals. He is passionate about continuing to grow within the firm, developing his experience and contributing to the wider team to support clients and their goals.

Outside of work, Liam enjoys playing golf, catching up with mates and playing football for Thomson Football Club.

Cooper Lynch

Cooper Lynch

Junior Accountant

Currently studying a Bachelor of Business at Deakin University

Cooper works across a range of accounting and tax work while continuing to build his experience as part of the Scotts team. He enjoys developing his skills, learning about different businesses and contributing to the wider team to support clients.

Outside of work, Cooper enjoys spending time with friends, following football and basketball and travelling. He also plays football for Thomson Football Club.

Cooper Lynch

Ziggy Lee

Junior Accountant

Currently studying a Bachelor of Commerce, majoring in Accounting

Ziggy works across a range of accounting and tax work, including tax returns, financial statements and Business Activity Statements, while continuing to build his experience as part of the Scotts team. He enjoys learning about different businesses, developing his technical skills and working alongside the wider team to support clients.

Outside of work, Ziggy plays football for Leopold and is a passionate Essendon supporter.

Ruby Saunders

Ruby Saunders

Administration Assistant

Ruby joined Scotts in February 2024 after moving to Geelong from Northeast Victoria, where she previously worked for a local accounting firm as a receptionist.

She provides administrative support across the wider team, including greeting clients, managing incoming phone calls and emails and scheduling appointments. Ruby always aims to be as efficient as possible so clients and staff can get what they need, when they need it.

What Ruby enjoys most about working at Scotts is that every day is different and being part of a close knit team that supports each other.

Outside of work, Ruby enjoys spending time with family and friends and going to the beach.

Ruby Saunders

Ella Cooper

Administration Assistant

Ella supports the wider Scotts team across a range of administrative tasks and enjoys building positive relationships with clients over the phone and by email.

Her role includes collating tax packages, data entry, managing bookings and helping direct client queries to the right person within the team.

Outside of work, Ella enjoys arts and crafts, photography and taking time to relax.

Claire Markewicz

Claire Surace

Administration Assistant

Claire supports the team across a broad range of administrative functions, including accounts payable and receivable, ASIC compliance and the administration of the firm’s trust account.

She is responsible for helping ensure financial transactions are processed accurately, regulatory obligations are met and trust account records are properly maintained.

Outside of work, Claire is usually kept busy running around after her son, Lenny. She also enjoys reading, cooking and relaxing in her spare time.

Mercedes Perez

Mercedes Perez

Receptionist

Certificate IV in Office Administration

Mercedes joined Scotts in November 2022 and is often one of the first points of contact for clients visiting or calling the office. She supports the wider team across reception and administration, including managing phone calls, appointments, client queries and the day to day running of the front office.

Mercedes is energetic, friendly and enjoys building strong relationships with clients and supporting the team wherever she can. She values being part of a close knit team and contributing to a positive experience for everyone who comes through the office.

She also makes a great coffee.