In a submission to the parliamentary panel entrusted with investigating the census debacle on 9 August, the Australian Privacy Foundation said the ABS' proposal to use statistical linkage keys (SLKs) for citizens' data had not been explained or evaluated for privacy risks.
The submission was made on 27 September, six days after the expiry of the 21 September deadline, but the APF said it had been granted an extension to make a late submission.
"The Parliament should ensure that the Senate inquiry concentrates on restoring public trust by ensuring the census does not compromise the privacy of Australians," said Kat Lane, vice-chair of the APF, adding, "The ABS's incompetence in running the census is a secondary issue."
In its submission, the APF said it was also concerned about reports by Australians of harassment by ABS agents. "The APF believes it is unacceptable to threaten Australians with fines when they have legitimate concerns about the census," Lane said.
The APF recommended that the ABS be required to delete all names and other direct identifiers such as SLKs from personal data collected and commission a privacy impact assessment for any proposed changes to the census that could affect citizens' privacy.
It also asked the Senate panel to recommend that the Census and Statistics Act 1905 be amended to preclude the ABS from gathering, retaining, and disclosing identifiable personal data.
Another recommendation was for the Act to be amended to ensure that the use of personal data be limited to generating statistical data, and scope creep, with deliberate use of data which could identify individuals, be precluded by law.
The APF also asked that the ABS be prohibited from misleading, threatening, harassing and coercing individual Australians and that daily fines be repealed to restore the trust of the public in the Census.
It said a one-off nominal fine for failing to complete the census was permissible, provided there was an exemption for exceptional circumstances.
The APF asked that that the Act be amended to preclude retention of census or survey data collected in a personally identifiable form by ABS or any other organisation.
It also wanted independent external audits to be conducted regularly to ensure the security of census data.