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The Office of the Australian Information Commissioner (OAIC) undertook a privacy assessment of the Coles flybuys loyalty program (flybuys) 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 flybuys was adequately describing its main uses and disclosures of information, particularly in relation to any analytical or ‘big data’ activities, in its privacy notices.

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