The Office of the Australian Information Commissioner (OAIC) undertook a privacy assessment of the Woolworths loyalty program (Woolworths Rewards) to assess whether the program:

• managed personal information in an open and transparent way as required by Australian Privacy Principle (APP) 1
• notified individuals of the collection of personal information in accordance with its APP 5 obligations.

The assessment also considered whether Woolworths Rewards was adequately describing its main uses and disclosures of information, particularly in relation to any analytical or ‘big data’ activities, in its privacy notices.