AI Compliance Checklist
Reference
Purpose: Ensure AI projects comply with Australian Government requirements, legislation, and frameworks. Use throughout the project lifecycle to verify compliance and document evidence.
Checklist Coverage
- Ethics: All 8 AI Ethics Principles
- Privacy: Privacy Act, APPs
- Security: PSPF, ISM requirements
- Accessibility: WCAG, DTA standards
Living Document
This checklist should be maintained throughout your project. Review at each phase gate and update as requirements change.
How to Use This Checklist
- Complete relevant sections based on project phase
- Document evidence for each item
- Escalate any gaps to appropriate stakeholders
- Review with governance bodies as required
- Maintain as a living document
Compliance Status: - [ ] Not Started - [~] In Progress - [x] Complete - [N/A] Not Applicable
Section 1: Australian Government AI Ethics Framework
1.1 Human, Societal and Environmental Wellbeing
| # | Requirement | Status | Evidence | Notes |
| 1.1.1 | Benefits and risks to individuals assessed | [ ] | | |
| 1.1.2 | Societal impacts considered | [ ] | | |
| 1.1.3 | Environmental impact assessed | [ ] | | |
| 1.1.4 | Net benefit demonstrated | [ ] | | |
1.2 Human-Centred Values
| # | Requirement | Status | Evidence | Notes |
| 1.2.1 | Respects human rights | [ ] | | |
| 1.2.2 | Respects diversity | [ ] | | |
| 1.2.3 | Supports individual autonomy | [ ] | | |
| 1.2.4 | User research conducted | [ ] | | |
1.3 Fairness
| # | Requirement | Status | Evidence | Notes |
| 1.3.1 | Bias testing conducted | [ ] | | |
| 1.3.2 | Fairness metrics defined and met | [ ] | | |
| 1.3.3 | Inclusive design applied | [ ] | | |
| 1.3.4 | Discrimination risks mitigated | [ ] | | |
1.4 Privacy Protection and Security
| # | Requirement | Status | Evidence | Notes |
| 1.4.1 | Privacy Impact Assessment completed | [ ] | | |
| 1.4.2 | Data minimization applied | [ ] | | |
| 1.4.3 | Security assessment completed | [ ] | | |
| 1.4.4 | Access controls implemented | [ ] | | |
1.5 Reliability and Safety
| # | Requirement | Status | Evidence | Notes |
| 1.5.1 | Testing comprehensive | [ ] | | |
| 1.5.2 | Monitoring implemented | [ ] | | |
| 1.5.3 | Fallback mechanisms in place | [ ] | | |
| 1.5.4 | Safe failure modes defined | [ ] | | |
1.6 Transparency and Explainability
| # | Requirement | Status | Evidence | Notes |
| 1.6.1 | AI use disclosed to affected people | [ ] | | |
| 1.6.2 | Explanations available | [ ] | | |
| 1.6.3 | Model card completed | [ ] | | |
| 1.6.4 | Limitations documented | [ ] | | |
1.7 Contestability
| # | Requirement | Status | Evidence | Notes |
| 1.7.1 | Challenge mechanism exists | [ ] | | |
| 1.7.2 | Human review available | [ ] | | |
| 1.7.3 | Appeal process documented | [ ] | | |
| 1.7.4 | Contact point identified | [ ] | | |
1.8 Accountability
| # | Requirement | Status | Evidence | Notes |
| 1.8.1 | Clear ownership assigned | [ ] | | |
| 1.8.2 | Governance structure in place | [ ] | | |
| 1.8.3 | Audit trail maintained | [ ] | | |
| 1.8.4 | Responsibility for outcomes clear | [ ] | | |
Section 2: Privacy Act 1988 Compliance
2.1 Australian Privacy Principles (APPs)
| APP | Requirement | Status | Evidence | Notes |
| APP 1 | Open and transparent management of personal information | [ ] | | |
| APP 2 | Anonymity and pseudonymity options | [ ] | | |
| APP 3 | Collection of solicited personal information | [ ] | | |
| APP 4 | Dealing with unsolicited personal information | [ ] | | |
| APP 5 | Notification of collection | [ ] | | |
| APP 6 | Use or disclosure of personal information | [ ] | | |
| APP 7 | Direct marketing restrictions | [ ] | | |
| APP 8 | Cross-border disclosure of personal information | [ ] | | |
| APP 9 | Adoption, use or disclosure of government identifiers | [ ] | | |
| APP 10 | Quality of personal information | [ ] | | |
| APP 11 | Security of personal information | [ ] | | |
| APP 12 | Access to personal information | [ ] | | |
| APP 13 | Correction of personal information | [ ] | | |
2.2 Privacy Assessment
| # | Requirement | Status | Evidence | Notes |
| 2.2.1 | Privacy threshold assessment completed | [ ] | | |
| 2.2.2 | PIA completed (if required) | [ ] | | |
| 2.2.3 | Privacy risks documented | [ ] | | |
| 2.2.4 | Privacy controls implemented | [ ] | | |
| 2.2.5 | Privacy notice updated | [ ] | | |
Section 3: Protective Security Policy Framework (PSPF)
| # | Requirement | Status | Evidence | Notes |
| 3.1.1 | Information classified correctly | [ ] | | |
| 3.1.2 | Handling requirements met | [ ] | | |
| 3.1.3 | Access controls appropriate | [ ] | | |
| 3.1.4 | Transmission security adequate | [ ] | | |
3.2 Personnel Security
| # | Requirement | Status | Evidence | Notes |
| 3.2.1 | Staff clearances appropriate | [ ] | | |
| 3.2.2 | Vendor personnel cleared | [ ] | | |
| 3.2.3 | Training completed | [ ] | | |
3.3 Physical Security
| # | Requirement | Status | Evidence | Notes |
| 3.3.1 | Physical access controlled | [ ] | | |
| 3.3.2 | Equipment secured | [ ] | | |
4.1 General Controls
| # | Requirement | Status | Evidence | Notes |
| 4.1.1 | Risk assessment completed | [ ] | | |
| 4.1.2 | Security plan documented | [ ] | | |
| 4.1.3 | Incident response plan in place | [ ] | | |
4.2 Access Control
| # | Requirement | Status | Evidence | Notes |
| 4.2.1 | Principle of least privilege applied | [ ] | | |
| 4.2.2 | Multi-factor authentication (where required) | [ ] | | |
| 4.2.3 | Access reviews scheduled | [ ] | | |
4.3 Software Security
| # | Requirement | Status | Evidence | Notes |
| 4.3.1 | Secure development practices | [ ] | | |
| 4.3.2 | Code review completed | [ ] | | |
| 4.3.3 | Vulnerability assessment done | [ ] | | |
| 4.3.4 | Penetration testing (if required) | [ ] | | |
4.4 Data Security
| # | Requirement | Status | Evidence | Notes |
| 4.4.1 | Data encrypted at rest | [ ] | | |
| 4.4.2 | Data encrypted in transit | [ ] | | |
| 4.4.3 | Key management in place | [ ] | | |
| 4.4.4 | Data backup and recovery | [ ] | | |
4.5 Network Security
| # | Requirement | Status | Evidence | Notes |
| 4.5.1 | Network segmentation | [ ] | | |
| 4.5.2 | Firewall rules documented | [ ] | | |
| 4.5.3 | Intrusion detection/prevention | [ ] | | |
Section 5: Digital Service Standard
5.1 User-Centred Design
| # | Requirement | Status | Evidence | Notes |
| 5.1.1 | User needs researched | [ ] | | |
| 5.1.2 | User testing conducted | [ ] | | |
| 5.1.3 | Iterative development | [ ] | | |
| 5.1.4 | Feedback mechanisms in place | [ ] | | |
5.2 Accessibility (WCAG 2.1)
| # | Requirement | Status | Evidence | Notes |
| 5.2.1 | WCAG 2.1 AA compliance | [ ] | | |
| 5.2.2 | Accessibility testing completed | [ ] | | |
| 5.2.3 | Assistive technology compatible | [ ] | | |
Section 6: Anti-Discrimination Legislation
6.1 Non-Discrimination
| # | Requirement | Legislation | Status | Evidence |
| 6.1.1 | Age discrimination prevented | Age Discrimination Act 2004 | [ ] | |
| 6.1.2 | Disability discrimination prevented | Disability Discrimination Act 1992 | [ ] | |
| 6.1.3 | Sex discrimination prevented | Sex Discrimination Act 1984 | [ ] | |
| 6.1.4 | Racial discrimination prevented | Racial Discrimination Act 1975 | [ ] | |
| 6.1.5 | Indirect discrimination considered | Various | [ ] | |
Section 7: Administrative Law
7.1 Decision-Making Requirements
| # | Requirement | Status | Evidence | Notes |
| 7.1.1 | Proper authority for decision | [ ] | | |
| 7.1.2 | Relevant considerations applied | [ ] | | |
| 7.1.3 | Irrelevant considerations excluded | [ ] | | |
| 7.1.4 | Procedural fairness observed | [ ] | | |
| 7.1.5 | Reasons for decision available | [ ] | | |
| 7.1.6 | Review rights communicated | [ ] | | |
7.2 Automated Decision-Making
| # | Requirement | Status | Evidence | Notes |
| 7.2.1 | Legal authority for automation | [ ] | | |
| 7.2.2 | Human oversight appropriate | [ ] | | |
| 7.2.3 | Manual override possible | [ ] | | |
| 7.2.4 | Audit trail maintained | [ ] | | |
Section 8: Data Governance
8.1 Data Management
| # | Requirement | Status | Evidence | Notes |
| 8.1.1 | Data ownership defined | [ ] | | |
| 8.1.2 | Data quality standards met | [ ] | | |
| 8.1.3 | Data catalogue entry created | [ ] | | |
| 8.1.4 | Retention schedule applied | [ ] | | |
| 8.1.5 | Disposal procedures in place | [ ] | | |
8.2 Data Sharing
| # | Requirement | Status | Evidence | Notes |
| 8.2.1 | Data sharing agreements | [ ] | | |
| 8.2.2 | Third-party access controlled | [ ] | | |
| 8.2.3 | Cross-agency sharing authorized | [ ] | | |
Section 9: Cloud and Hosting
9.1 Cloud Security
| # | Requirement | Status | Evidence | Notes |
| 9.1.1 | Cloud provider on approved list | [ ] | | |
| 9.1.2 | Data sovereignty (Australian data centers) | [ ] | | |
| 9.1.3 | Cloud security assessment | [ ] | | |
| 9.1.4 | Shared responsibility understood | [ ] | | |
Section 10: Procurement and Contracts
10.1 Vendor Requirements
| # | Requirement | Status | Evidence | Notes |
| 10.1.1 | Vendor security assessment | [ ] | | |
| 10.1.2 | Subprocessors documented | [ ] | | |
| 10.1.3 | AI-specific contract clauses | [ ] | | |
| 10.1.4 | Exit/transition provisions | [ ] | | |
| 10.1.5 | IP ownership clarified | [ ] | | |
Summary Assessment
Compliance Status by Section
| Section | Items | Complete | In Progress | Not Started | N/A |
| AI Ethics Framework | | | | | |
| Privacy Act | | | | | |
| PSPF | | | | | |
| ISM | | | | | |
| Digital Service Standard | | | | | |
| Anti-Discrimination | | | | | |
| Administrative Law | | | | | |
| Data Governance | | | | | |
| Cloud Security | | | | | |
| Procurement | | | | | |
| TOTAL | | | | | |
Outstanding Items
| Item | Owner | Due Date | Priority |
| | | High/Med/Low |
| | | |
| | | |
Risk Assessment
| Gap | Risk Level | Mitigation | Timeline |
| High/Med/Low | | |
| | | |
Sign-Off
| Role | Name | Date | Sign-Off |
| Project Manager | | | [ ] |
| Privacy Officer | | | [ ] |
| Security Officer | | | [ ] |
| Legal Counsel | | | [ ] |
| Ethics Lead | | | [ ] |
Version History
| Version | Date | Author | Changes |
| 1.0 | | | Initial checklist |
| | | |