Fractional Privacy Officer Services

Name: Click Legal Legal & Compliance Services
Brand: Click Legal
Rating: 5 (37 reviews)

We act as your senior privacy & data protection partner for APP entities & data-heavy regulated businesses, without the cost of a full-time Privacy Officer.

Your Fractional Privacy Officer Partner

Click Legal is a specialist Australian law firm. We take ownership of your privacy framework so you can focus on running the business. As your fractional Privacy Officer, we step in where a full-time privacy lead would usually sit, without the permanent headcount.

We support you across the full privacy lifecycle: Privacy Act & APP compliance, data mapping & DPIAs, third-party & cross-border data sharing, NDB scheme response & OAIC-facing work. You get senior, business-first privacy leadership on a flexible, fixed-fee basis.

What We Do As Your Fractional Privacy Officer

As your fractional Privacy Officer, we provide ongoing privacy governance & execution support tailored to your data footprint, products & risk profile. We combine policy & framework work with practical oversight of data flows, incidents & training so privacy is managed deliberately, not left to chance.

01. Privacy Governance & Framework

We design & maintain a privacy framework that aligns with the Privacy Act & APPs, by:

drafting & updating privacy policies, procedures, notices & internal guidelines;
clarifying roles, responsibilities & approval pathways for privacy decisions;
integrating privacy oversight into your existing governance & risk structures.

02. Data Mapping, DPIAs & High-Risk Processing

We help you understand & assess how personal information is used across your business, by:

mapping what data you collect, where it is stored, who it is shared with & for what purposes;
overseeing privacy impact assessments (PIAs/DPIAs) for new products, features & data uses;
flagging higher-risk processing & recommending practical controls before launch.

03. Third-Party, CDR & Cross-Border Data Sharing

We oversee privacy aspects of your vendor & partner ecosystem, by:

reviewing & negotiating data protection clauses with service providers & partners;
managing privacy considerations in CDR/open banking & other data-sharing arrangements;
ensuring cross-border disclosures & offshore support arrangements are documented & compliant.

04. Data Breach & NDB Scheme Response

We coordinate your response when things go wrong, by:

maintaining & refining your data breach response playbook & incident registers;
triaging suspected breaches, assessing serious harm risk & deciding if NDB notification is required;
coordinating notifications to OAIC & affected individuals, & feeding lessons back into controls.

05. Training, Culture & Board Reporting

We connect day-to-day privacy work with people & governance, by:

designing role-based privacy training for staff, product teams & leaders;
preparing regular privacy reports for boards & committees with clear status & key risks;
keeping a simple improvement backlog from incidents, PIAs & audits, & helping you work through it over time.

Who We Advise

We act for data-heavy, regulated organisations where privacy, data protection & NDB readiness are not optional. If you hold significant customer or investor information, operate under the Privacy Act & APPs (& increasingly CDR/open banking), a full-time Privacy Officer may feel premature – but leaving privacy spread across legal, IT & operations is no longer safe.

Our fractional Privacy Officer service is designed for businesses that want a named, accountable privacy lead on call: someone who understands your products, data flows & regulatory settings, works alongside your team & stays with you as you grow.

Clients we act for include:

Lenders, credit providers & digital banks

Wealth & financial advice licensees

AFSL product issuers & investment platforms

Payments gateways & merchant platforms

Remittance & cross-border payment providers

Fintechs & embedded finance platforms

Digital currency exchanges & VASP platforms

Carbon, ESG & specialist asset managers

Our Clients Include

Discuss Your Fractional Privacy Officer Needs

Our senior lawyers will contact you to discuss your privacy framework, data footprint & NDB/APP obligations & outline clear next steps.

Fractional Privacy Officer Subscription Plans

Inclusions

Basic

Standard

Enhanced

Premium

Enterprise

$1,000/mo. +GST

$2,000/mo. +GST

$3,000/mo. +GST

$4,000/mo. +GST

$5,000/mo. +GST

Named Privacy Officer

Learn More

A Named Lead, Not Just an Adviser

We act as your named Privacy Officer. This meets the governance expectation in APP 1 and OAIC guidance.

We are your point of contact with the OAIC on day-to-day privacy matters.

Included

Nomination as your Privacy Officer. Ongoing oversight and operational arrangement of your privacy obligations.

Frequency

Ongoing.

CAPS

An oversight role. Your team keeps day-to-day tasks, such as handling routine access requests.

Out of scope

Acting as your organisation for regulatory purposes. You remain the APP entity.

Learn More

Keeping Your Framework Current

We maintain your privacy policy and privacy management framework, aligned with the Australian Privacy Principles and current OAIC guidance.

Included

Review and maintenance of your existing privacy policy and framework.

Frequency

Ongoing. Reviewed at least once a year, or after a material change in your business.

CAPS

Maintenance of an existing framework only.

Out of scope

Drafting a new framework from scratch. A full rewrite after a material change is quoted separately.

Hands-On Implementation Support

Learn More

Putting the Framework into Practice

We help your team use the framework day to day. This can include setting up your privacy folders or answering set-up questions.

Included

Up to 2 sessions of 90 minutes per month. Virtual or onsite.

Frequency

Monthly.

CAPS

3 hours total per month. Additional hours are billed at our standard hourly rates, available on request.

Out of scope

Ongoing operational tasks, such as data entry into registers.

Privacy Registers and Templates

Learn More

The Working Tools You Need

We set up the registers you need to evidence compliance.

Examples include a data breach register, complaints register, and personal information holdings register.

Included

Up to 3 template registers. Excel or Word based.

Frequency

One-off setup, in the first month.

CAPS

Standard templates only. Custom-built databases are extra.

Out of scope

Populating registers with your historical data.

Privacy Impact Assessment Support

Learn More

Checking New Projects before launch

We review new projects, systems or vendors for privacy risk. We check they align with your privacy framework.

Included

Review of up to 2 Privacy Impact Assessments per quarter.

Frequency

Quarterly.

CAPS

Review of a completed draft. Running stakeholder workshops is extra.

Out of scope

Drafting the Privacy Impact Assessment from scratch.

Privacy Reporting Support

Learn More

Reporting to Your Board

We help you prepare privacy reports for your board or senior management.

Included

Review and input on 1 draft report per quarter.

Frequency

Quarterly.

CAPS

Up to 1 hour of review per quarter. Drafting from scratch is extra.

Out of scope

Independent audit of the report’s accuracy.

Standard Staff Privacy Training

Learn More

General Awareness Training

A pre-prepared session on general privacy topics. For example, an introduction to the Australian Privacy Principles.

Included

One 60-minute virtual session, for up to 20 staff, per quarter.

Frequency

Quarterly.

CAPS

Standard slides only. Customised content is extra.

Out of scope

Role-specific training, such as separate content for marketing teams.

Annual Review of Your Privacy Framework

Learn More

A Yearly Health Check

Once a year, we check your privacy policy and framework are still current. We send you a short summary.

Included

Review of your privacy policy and framework. A health-check email.

Frequency

Annual.

CAPS

Review only. Major rewrites after a law change are separate.

Out of scope

A formal privacy audit or external certification.

Regulatory Update Briefings

Learn More

Staying Ahead of the OAIC

A short call to flag anything new. This covers OAIC guidance and Privacy Act changes from the last quarter.

Included

One 30-minute call per quarter.

Frequency

Quarterly.

CAPS

General updates only. A major project arising from a change is scoped separately.

Out of scope

Implementing the changes for you.

Monthly Strategy Session

Learn More

Talking Strategy, Not Just Compliance

A monthly meeting on your business priorities. We talk through how to manage privacy risk as you grow.

Included

One 60-minute call per month.

Frequency

Monthly.

CAPS

Strategy only. Work arising from the call uses your monthly hours.

Out of scope

Execution of strategy, such as running a project.

Data Breach Response Oversight

Learn More

Overseeing How a Breach Is Handled

We oversee how a suspected data breach is assessed and reported. This covers the Notifiable Data Breaches scheme timeframes.

Included

Guidance on eligible data breach assessment. Oversight of OAIC and individual notifications. Up to 4 hours per month.

Frequency

Monthly.

CAPS

4 hours per month. A major breach response is scoped separately.

Out of scope

Being your first-line incident response or IT forensics team.

Tailored Privacy Training for Staff

Learn More

Training Built Around Your Risks

Bespoke training for your business. We build a session around your actual data, systems and risks.

Included

One 90-minute tailored session per quarter.

Frequency

Quarterly.

CAPS

Up to 20 attendees. Extra sessions quoted separately.

Out of scope

Training for specialist roles, such as IT security.

Dedicated Support Line

Learn More

A Direct Line When You Need One

A direct line for quick questions. For example, whether an access request is valid.

Included

Up to 8 short advice touches per month. Calls or emails.

Frequency

Monthly.

CAPS

20 minutes per touch. Longer matters move to project work.

Out of scope

Drafting documents on the call.

Additional Privacy Documentation

Learn More

Beyond the Core Framework

We draft other documents you need. Examples include data sharing agreements and vendor privacy addenda.

Included

Up to 3 additional standard documents per quarter.

Frequency

Quarterly, up to 12 per year.

CAPS

Standard templates or minor changes only.

Out of scope

Bespoke, high-value legal agreements.

Ongoing Strategic Privacy Consultation

Learn More

A Seat at the Table

We act as your executive Privacy Officer. We advise on privacy and data risk at a strategic level.

Included

Two 60-minute strategic sessions per month.

Frequency

Monthly.

CAPS

Strategy and advice only. Execution, such as a new data project, is project work.

Out of scope

Representing you in negotiations.

OAIC and Regulator Engagement

Learn More

Support If the OAIC Comes Calling

If the OAIC contacts you for a compliance check or a complaint, we help you prepare and attend meetings.

Included

Review of 2 draft responses per year. A 60-minute prep call per event.

Frequency

As needed, up to 2 events per year.

CAPS

2 events. Formal representation at a hearing is separate.

Out of scope

Defending against enforcement action or penalties.

Legacy Items and Remediation

Learn More

Always Out of Scope

Legacy items and remediation plans sit outside every plan. This includes historical issues and clearing a backlog.

Out of scope

Legacy privacy issues, remediation plans, and remediation project work. Quoted separately, once we understand the scope.

Click Legal Portal

Learn More

Full access to our Click Legal Portal. This is our legal and compliance library of over 300 templates, checklists and guides, plus training material.

Compass by Click Legal

Learn More

Our monthly regulatory intelligence publication, for regulated financial services businesses. Each edition covers key legal and regulatory developments, with practical next steps.

Minimum Term: 6 Months

Learn More

Every Click Legal fractional officer role carries a 6-month minimum term. This applies to General Counsel, AML/CTF Compliance Officer, Complaints Officer, and Privacy Officer. These are regulated, accountable functions, not short-term project work. The term allows proper onboarding into your risk profile and history. It covers at least one full compliance cycle.

Terms: All plans can be tailored to your business. Prices are estimates for small to medium-size businesses. Final pricing depends on your size, complexity and data risk profile. We reserve the right to give a custom quote. A general compliance enquiry is a question answered by email or on a call, without a document review. Tailored documents are simple documents drafted for your business. Complex documents, and anything above your monthly numbers, are quoted separately as a fixed fee. Your privacy registers are built from the information you give us. Legacy items and remediation plans are out of scope under every plan and are quoted separately once we understand the scope.

Fractional General Counsel, Compliance Officer, AML/CTF Compliance Officer and Complaints Officer sit outside these plans. They are available separately. All fees are in Australian dollars per month and exclude GST.

Our plans are flexible

These plans are a starting point and can be tailored to suit your business. No two businesses need the same mix of reviews and briefings each month, and we do not expect yours to. If a month runs heavier than usual, for example a data breach, we tell you before we start the work. We either carry it into the following month or quote it as a fixed fee. Nothing is done quietly and charged to you later. If your needs sit between two plans, we build the plan around what you actually need. At the end of each six-month term, we review how the plan has worked and adjust it with you.

Basic

$1,000/mo. +GST

Named Privacy Officer

All plans

A Named Lead, Not Just an Adviser

We act as your named Privacy Officer. This meets the governance expectation in APP 1 and OAIC guidance.

We are your point of contact with the OAIC on day-to-day privacy matters.

Included

Nomination as your Privacy Officer. Ongoing oversight and operational arrangement of your privacy obligations.

Frequency

Ongoing.

CAPS

An oversight role. Your team keeps day-to-day tasks, such as handling routine access requests.

Out of scope

Acting as your organisation for regulatory purposes. You remain the APP entity.

Privacy Policy and Framework Maintained

All plans

Keeping Your Framework Current

We maintain your privacy policy and privacy management framework, aligned with the Australian Privacy Principles and current OAIC guidance.

Included

Review and maintenance of your existing privacy policy and framework.

Frequency

Ongoing. Reviewed at least once a year, or after a material change in your business.

CAPS

Maintenance of an existing framework only.

Out of scope

Drafting a new framework from scratch. A full rewrite after a material change is quoted separately.

Hands-On Implementation Support

Included in Standard, Enhanced, Premium, Enterprise

Putting the Framework into Practice

We help your team use the framework day to day. This can include setting up your privacy folders or answering set-up questions.

Included

Up to 2 sessions of 90 minutes per month. Virtual or onsite.

Frequency

Monthly.

CAPS

3 hours total per month. Additional hours are billed at our standard hourly rates, available on request.

Out of scope

Ongoing operational tasks, such as data entry into registers.

Privacy Registers and Templates

Included in Standard, Enhanced, Premium, Enterprise

The Working Tools You Need

We set up the registers you need to evidence compliance.

Examples include a data breach register, complaints register, and personal information holdings register.

Included

Up to 3 template registers. Excel or Word based.

Frequency

One-off setup, in the first month.

CAPS

Standard templates only. Custom-built databases are extra.

Out of scope

Populating registers with your historical data.

Privacy Impact Assessment Support

Included in Standard, Enhanced, Premium, Enterprise

Checking New Projects before launch

We review new projects, systems or vendors for privacy risk. We check they align with your privacy framework.

Included

Review of up to 2 Privacy Impact Assessments per quarter.

Frequency

Quarterly.

CAPS

Review of a completed draft. Running stakeholder workshops is extra.

Out of scope

Drafting the Privacy Impact Assessment from scratch.

Privacy Reporting Support

Included in Standard, Enhanced, Premium, Enterprise

Reporting to Your Board

We help you prepare privacy reports for your board or senior management.

Included

Review and input on 1 draft report per quarter.

Frequency

Quarterly.

CAPS

Up to 1 hour of review per quarter. Drafting from scratch is extra.

Out of scope

Independent audit of the report’s accuracy.

Standard Staff Privacy Training

Included in Standard, Enhanced, Premium, Enterprise

General Awareness Training

A pre-prepared session on general privacy topics. For example, an introduction to the Australian Privacy Principles.

Included

One 60-minute virtual session, for up to 20 staff, per quarter.

Frequency

Quarterly.

CAPS

Standard slides only. Customised content is extra.

Out of scope

Role-specific training, such as separate content for marketing teams.

Click Legal Portal

All plans

Full access to our Click Legal Portal. This is our legal and compliance library of over 300 templates, checklists and guides, plus training material.

Compass by Click Legal

Named Privacy Officer

All plans

A Named Lead, Not Just an Adviser

We act as your named Privacy Officer. This meets the governance expectation in APP 1 and OAIC guidance.

We are your point of contact with the OAIC on day-to-day privacy matters.

Included

Nomination as your Privacy Officer. Ongoing oversight and operational arrangement of your privacy obligations.

Frequency

Ongoing.

CAPS

An oversight role. Your team keeps day-to-day tasks, such as handling routine access requests.

Out of scope

Acting as your organisation for regulatory purposes. You remain the APP entity.

Privacy Policy and Framework Maintained

All plans

Keeping Your Framework Current

We maintain your privacy policy and privacy management framework, aligned with the Australian Privacy Principles and current OAIC guidance.

Included

Review and maintenance of your existing privacy policy and framework.

Frequency

Ongoing. Reviewed at least once a year, or after a material change in your business.

CAPS

Maintenance of an existing framework only.

Out of scope

Drafting a new framework from scratch. A full rewrite after a material change is quoted separately.

Hands-On Implementation Support

Included in Standard, Enhanced, Premium, Enterprise

Putting the Framework into Practice

We help your team use the framework day to day. This can include setting up your privacy folders or answering set-up questions.

Included

Up to 2 sessions of 90 minutes per month. Virtual or onsite.

Frequency

Monthly.

CAPS

3 hours total per month. Additional hours are billed at our standard hourly rates, available on request.

Out of scope

Ongoing operational tasks, such as data entry into registers.

Privacy Registers and Templates

Included in Standard, Enhanced, Premium, Enterprise

The Working Tools You Need

We set up the registers you need to evidence compliance.

Examples include a data breach register, complaints register, and personal information holdings register.

Included

Up to 3 template registers. Excel or Word based.

Frequency

One-off setup, in the first month.

CAPS

Standard templates only. Custom-built databases are extra.

Out of scope

Populating registers with your historical data.

Privacy Impact Assessment Support

Included in Standard, Enhanced, Premium, Enterprise

Checking New Projects before launch

We review new projects, systems or vendors for privacy risk. We check they align with your privacy framework.

Included

Review of up to 2 Privacy Impact Assessments per quarter.

Frequency

Quarterly.

CAPS

Review of a completed draft. Running stakeholder workshops is extra.

Out of scope

Drafting the Privacy Impact Assessment from scratch.

Privacy Reporting Support

Included in Standard, Enhanced, Premium, Enterprise

Reporting to Your Board

We help you prepare privacy reports for your board or senior management.

Included

Review and input on 1 draft report per quarter.

Frequency

Quarterly.

CAPS

Up to 1 hour of review per quarter. Drafting from scratch is extra.

Out of scope

Independent audit of the report’s accuracy.

Standard Staff Privacy Training

Included in Standard, Enhanced, Premium, Enterprise

General Awareness Training

A pre-prepared session on general privacy topics. For example, an introduction to the Australian Privacy Principles.

Included

One 60-minute virtual session, for up to 20 staff, per quarter.

Frequency

Quarterly.

CAPS

Standard slides only. Customised content is extra.

Out of scope

Role-specific training, such as separate content for marketing teams.

Click Legal Portal

All plans

Full access to our Click Legal Portal. This is our legal and compliance library of over 300 templates, checklists and guides, plus training material.

Compass by Click Legal

Named Privacy Officer

All plans

A Named Lead, Not Just an Adviser

We act as your named Privacy Officer. This meets the governance expectation in APP 1 and OAIC guidance.

We are your point of contact with the OAIC on day-to-day privacy matters.

Included

Nomination as your Privacy Officer. Ongoing oversight and operational arrangement of your privacy obligations.

Frequency

Ongoing.

CAPS

An oversight role. Your team keeps day-to-day tasks, such as handling routine access requests.

Out of scope

Acting as your organisation for regulatory purposes. You remain the APP entity.

Privacy Policy and Framework Maintained

All plans

Keeping Your Framework Current

We maintain your privacy policy and privacy management framework, aligned with the Australian Privacy Principles and current OAIC guidance.

Included

Review and maintenance of your existing privacy policy and framework.

Frequency

Ongoing. Reviewed at least once a year, or after a material change in your business.

CAPS

Maintenance of an existing framework only.

Out of scope

Drafting a new framework from scratch. A full rewrite after a material change is quoted separately.

Hands-On Implementation Support

Included in Standard, Enhanced, Premium, Enterprise

Putting the Framework into Practice

We help your team use the framework day to day. This can include setting up your privacy folders or answering set-up questions.

Included

Up to 2 sessions of 90 minutes per month. Virtual or onsite.

Frequency

Monthly.

CAPS

3 hours total per month. Additional hours are billed at our standard hourly rates, available on request.

Out of scope

Ongoing operational tasks, such as data entry into registers.

Privacy Registers and Templates

Included in Standard, Enhanced, Premium, Enterprise

The Working Tools You Need

We set up the registers you need to evidence compliance.

Examples include a data breach register, complaints register, and personal information holdings register.

Included

Up to 3 template registers. Excel or Word based.

Frequency

One-off setup, in the first month.

CAPS

Standard templates only. Custom-built databases are extra.

Out of scope

Populating registers with your historical data.

Privacy Impact Assessment Support

Included in Standard, Enhanced, Premium, Enterprise

Checking New Projects before launch

We review new projects, systems or vendors for privacy risk. We check they align with your privacy framework.

Included

Review of up to 2 Privacy Impact Assessments per quarter.

Frequency

Quarterly.

CAPS

Review of a completed draft. Running stakeholder workshops is extra.

Out of scope

Drafting the Privacy Impact Assessment from scratch.

Privacy Reporting Support

Included in Standard, Enhanced, Premium, Enterprise

Reporting to Your Board

We help you prepare privacy reports for your board or senior management.

Included

Review and input on 1 draft report per quarter.

Frequency

Quarterly.

CAPS

Up to 1 hour of review per quarter. Drafting from scratch is extra.

Out of scope

Independent audit of the report’s accuracy.

Standard Staff Privacy Training

Included in Standard, Enhanced, Premium, Enterprise

General Awareness Training

A pre-prepared session on general privacy topics. For example, an introduction to the Australian Privacy Principles.

Included

One 60-minute virtual session, for up to 20 staff, per quarter.

Frequency

Quarterly.

CAPS

Standard slides only. Customised content is extra.

Out of scope

Role-specific training, such as separate content for marketing teams.

Annual Review of Your Privacy Framework

Included in Enhanced, Premium, Enterprise

A Yearly Health Check

Once a year, we check your privacy policy and framework are still current. We send you a short summary.

Included

Review of your privacy policy and framework. A health-check email.

Frequency

Annual.

CAPS

Review only. Major rewrites after a law change are separate.

Out of scope

A formal privacy audit or external certification.

Regulatory Update Briefings

Included in Enhanced, Premium, Enterprise

Staying Ahead of the OAIC

A short call to flag anything new. This covers OAIC guidance and Privacy Act changes from the last quarter.

Included

One 30-minute call per quarter.

Frequency

Quarterly.

CAPS

General updates only. A major project arising from a change is scoped separately.

Out of scope

Implementing the changes for you.

Monthly Strategy Session

Included in Enhanced, Premium, Enterprise

Talking Strategy, Not Just Compliance

A monthly meeting on your business priorities. We talk through how to manage privacy risk as you grow.

Included

One 60-minute call per month.

Frequency

Monthly.

CAPS

Strategy only. Work arising from the call uses your monthly hours.

Out of scope

Execution of strategy, such as running a project.

Click Legal Portal

All plans

Full access to our Click Legal Portal. This is our legal and compliance library of over 300 templates, checklists and guides, plus training material.

Compass by Click Legal

Named Privacy Officer

All plans

A Named Lead, Not Just an Adviser

We act as your named Privacy Officer. This meets the governance expectation in APP 1 and OAIC guidance.

We are your point of contact with the OAIC on day-to-day privacy matters.

Included

Nomination as your Privacy Officer. Ongoing oversight and operational arrangement of your privacy obligations.

Frequency

Ongoing.

CAPS

An oversight role. Your team keeps day-to-day tasks, such as handling routine access requests.

Out of scope

Acting as your organisation for regulatory purposes. You remain the APP entity.

Privacy Policy and Framework Maintained

All plans

Keeping Your Framework Current

We maintain your privacy policy and privacy management framework, aligned with the Australian Privacy Principles and current OAIC guidance.

Included

Review and maintenance of your existing privacy policy and framework.

Frequency

Ongoing. Reviewed at least once a year, or after a material change in your business.

CAPS

Maintenance of an existing framework only.

Out of scope

Drafting a new framework from scratch. A full rewrite after a material change is quoted separately.

Hands-On Implementation Support

Included in Standard, Enhanced, Premium, Enterprise

Putting the Framework into Practice

We help your team use the framework day to day. This can include setting up your privacy folders or answering set-up questions.

Included

Up to 2 sessions of 90 minutes per month. Virtual or onsite.

Frequency

Monthly.

CAPS

3 hours total per month. Additional hours are billed at our standard hourly rates, available on request.

Out of scope

Ongoing operational tasks, such as data entry into registers.

Privacy Registers and Templates

Included in Standard, Enhanced, Premium, Enterprise

The Working Tools You Need

We set up the registers you need to evidence compliance.

Examples include a data breach register, complaints register, and personal information holdings register.

Included

Up to 3 template registers. Excel or Word based.

Frequency

One-off setup, in the first month.

CAPS

Standard templates only. Custom-built databases are extra.

Out of scope

Populating registers with your historical data.

Privacy Impact Assessment Support

Included in Standard, Enhanced, Premium, Enterprise

Checking New Projects before launch

We review new projects, systems or vendors for privacy risk. We check they align with your privacy framework.

Included

Review of up to 2 Privacy Impact Assessments per quarter.

Frequency

Quarterly.

CAPS

Review of a completed draft. Running stakeholder workshops is extra.

Out of scope

Drafting the Privacy Impact Assessment from scratch.

Privacy Reporting Support

Included in Standard, Enhanced, Premium, Enterprise

Reporting to Your Board

We help you prepare privacy reports for your board or senior management.

Included

Review and input on 1 draft report per quarter.

Frequency

Quarterly.

CAPS

Up to 1 hour of review per quarter. Drafting from scratch is extra.

Out of scope

Independent audit of the report’s accuracy.

Standard Staff Privacy Training

Included in Standard, Enhanced, Premium, Enterprise

General Awareness Training

A pre-prepared session on general privacy topics. For example, an introduction to the Australian Privacy Principles.

Included

One 60-minute virtual session, for up to 20 staff, per quarter.

Frequency

Quarterly.

CAPS

Standard slides only. Customised content is extra.

Out of scope

Role-specific training, such as separate content for marketing teams.

Annual Review of Your Privacy Framework

Included in Enhanced, Premium, Enterprise

A Yearly Health Check

Once a year, we check your privacy policy and framework are still current. We send you a short summary.

Included

Review of your privacy policy and framework. A health-check email.

Frequency

Annual.

CAPS

Review only. Major rewrites after a law change are separate.

Out of scope

A formal privacy audit or external certification.

Regulatory Update Briefings

Included in Enhanced, Premium, Enterprise

Staying Ahead of the OAIC

A short call to flag anything new. This covers OAIC guidance and Privacy Act changes from the last quarter.

Included

One 30-minute call per quarter.

Frequency

Quarterly.

CAPS

General updates only. A major project arising from a change is scoped separately.

Out of scope

Implementing the changes for you.

Monthly Strategy Session

Included in Enhanced, Premium, Enterprise

Talking Strategy, Not Just Compliance

A monthly meeting on your business priorities. We talk through how to manage privacy risk as you grow.

Included

One 60-minute call per month.

Frequency

Monthly.

CAPS

Strategy only. Work arising from the call uses your monthly hours.

Out of scope

Execution of strategy, such as running a project.

Data Breach Response Oversight

Included in Premium, Enterprise

Overseeing How a Breach Is Handled

We oversee how a suspected data breach is assessed and reported. This covers the Notifiable Data Breaches scheme timeframes.

Included

Guidance on eligible data breach assessment. Oversight of OAIC and individual notifications. Up to 4 hours per month.

Frequency

Monthly.

CAPS

4 hours per month. A major breach response is scoped separately.

Out of scope

Being your first-line incident response or IT forensics team.

Tailored Privacy Training for Staff

Included in Premium, Enterprise

Training Built Around Your Risks

Bespoke training for your business. We build a session around your actual data, systems and risks.

Included

One 90-minute tailored session per quarter.

Frequency

Quarterly.

CAPS

Up to 20 attendees. Extra sessions quoted separately.

Out of scope

Training for specialist roles, such as IT security.

Dedicated Support Line

Included in Premium, Enterprise

A Direct Line When You Need One

A direct line for quick questions. For example, whether an access request is valid.

Included

Up to 8 short advice touches per month. Calls or emails.

Frequency

Monthly.

CAPS

20 minutes per touch. Longer matters move to project work.

Out of scope

Drafting documents on the call.

Click Legal Portal

All plans

Full access to our Click Legal Portal. This is our legal and compliance library of over 300 templates, checklists and guides, plus training material.

Compass by Click Legal

Named Privacy Officer

All plans

A Named Lead, Not Just an Adviser

We act as your named Privacy Officer. This meets the governance expectation in APP 1 and OAIC guidance.

We are your point of contact with the OAIC on day-to-day privacy matters.

Included

Nomination as your Privacy Officer. Ongoing oversight and operational arrangement of your privacy obligations.

Frequency

Ongoing.

CAPS

An oversight role. Your team keeps day-to-day tasks, such as handling routine access requests.

Out of scope

Acting as your organisation for regulatory purposes. You remain the APP entity.

Privacy Policy and Framework Maintained

All plans

Keeping Your Framework Current

We maintain your privacy policy and privacy management framework, aligned with the Australian Privacy Principles and current OAIC guidance.

Included

Review and maintenance of your existing privacy policy and framework.

Frequency

Ongoing. Reviewed at least once a year, or after a material change in your business.

CAPS

Maintenance of an existing framework only.

Out of scope

Drafting a new framework from scratch. A full rewrite after a material change is quoted separately.

Hands-On Implementation Support

Included in Standard, Enhanced, Premium, Enterprise

Putting the Framework into Practice

We help your team use the framework day to day. This can include setting up your privacy folders or answering set-up questions.

Included

Up to 2 sessions of 90 minutes per month. Virtual or onsite.

Frequency

Monthly.

CAPS

3 hours total per month. Additional hours are billed at our standard hourly rates, available on request.

Out of scope

Ongoing operational tasks, such as data entry into registers.

Privacy Registers and Templates

Included in Standard, Enhanced, Premium, Enterprise

The Working Tools You Need

We set up the registers you need to evidence compliance.

Examples include a data breach register, complaints register, and personal information holdings register.

Included

Up to 3 template registers. Excel or Word based.

Frequency

One-off setup, in the first month.

CAPS

Standard templates only. Custom-built databases are extra.

Out of scope

Populating registers with your historical data.

Privacy Impact Assessment Support

Included in Standard, Enhanced, Premium, Enterprise

Checking New Projects before launch

We review new projects, systems or vendors for privacy risk. We check they align with your privacy framework.

Included

Review of up to 2 Privacy Impact Assessments per quarter.

Frequency

Quarterly.

CAPS

Review of a completed draft. Running stakeholder workshops is extra.

Out of scope

Drafting the Privacy Impact Assessment from scratch.

Privacy Reporting Support

Included in Standard, Enhanced, Premium, Enterprise

Reporting to Your Board

We help you prepare privacy reports for your board or senior management.

Included

Review and input on 1 draft report per quarter.

Frequency

Quarterly.

CAPS

Up to 1 hour of review per quarter. Drafting from scratch is extra.

Out of scope

Independent audit of the report’s accuracy.

Standard Staff Privacy Training

Included in Standard, Enhanced, Premium, Enterprise

General Awareness Training

A pre-prepared session on general privacy topics. For example, an introduction to the Australian Privacy Principles.

Included

One 60-minute virtual session, for up to 20 staff, per quarter.

Frequency

Quarterly.

CAPS

Standard slides only. Customised content is extra.

Out of scope

Role-specific training, such as separate content for marketing teams.

Annual Review of Your Privacy Framework

Included in Enhanced, Premium, Enterprise

A Yearly Health Check

Once a year, we check your privacy policy and framework are still current. We send you a short summary.

Included

Review of your privacy policy and framework. A health-check email.

Frequency

Annual.

CAPS

Review only. Major rewrites after a law change are separate.

Out of scope

A formal privacy audit or external certification.

Regulatory Update Briefings

Included in Enhanced, Premium, Enterprise

Staying Ahead of the OAIC

A short call to flag anything new. This covers OAIC guidance and Privacy Act changes from the last quarter.

Included

One 30-minute call per quarter.

Frequency

Quarterly.

CAPS

General updates only. A major project arising from a change is scoped separately.

Out of scope

Implementing the changes for you.

Monthly Strategy Session

Included in Enhanced, Premium, Enterprise

Talking Strategy, Not Just Compliance

A monthly meeting on your business priorities. We talk through how to manage privacy risk as you grow.

Included

One 60-minute call per month.

Frequency

Monthly.

CAPS

Strategy only. Work arising from the call uses your monthly hours.

Out of scope

Execution of strategy, such as running a project.

Data Breach Response Oversight

Included in Premium, Enterprise

Overseeing How a Breach Is Handled

We oversee how a suspected data breach is assessed and reported. This covers the Notifiable Data Breaches scheme timeframes.

Included

Guidance on eligible data breach assessment. Oversight of OAIC and individual notifications. Up to 4 hours per month.

Frequency

Monthly.

CAPS

4 hours per month. A major breach response is scoped separately.

Out of scope

Being your first-line incident response or IT forensics team.

Tailored Privacy Training for Staff

Included in Premium, Enterprise

Training Built Around Your Risks

Bespoke training for your business. We build a session around your actual data, systems and risks.

Included

One 90-minute tailored session per quarter.

Frequency

Quarterly.

CAPS

Up to 20 attendees. Extra sessions quoted separately.

Out of scope

Training for specialist roles, such as IT security.

Dedicated Support Line

Included in Premium, Enterprise

A Direct Line When You Need One

A direct line for quick questions. For example, whether an access request is valid.

Included

Up to 8 short advice touches per month. Calls or emails.

Frequency

Monthly.

CAPS

20 minutes per touch. Longer matters move to project work.

Out of scope

Drafting documents on the call.

Additional Privacy Documentation

Included in Enterprise

Beyond the Core Framework

We draft other documents you need. Examples include data sharing agreements and vendor privacy addenda.

Included

Up to 3 additional standard documents per quarter.

Frequency

Quarterly, up to 12 per year.

CAPS

Standard templates or minor changes only.

Out of scope

Bespoke, high-value legal agreements.

Ongoing Strategic Privacy Consultation

Included in Enterprise

A Seat at the Table

We act as your executive Privacy Officer. We advise on privacy and data risk at a strategic level.

Included

Two 60-minute strategic sessions per month.

Frequency

Monthly.

CAPS

Strategy and advice only. Execution, such as a new data project, is project work.

Out of scope

Representing you in negotiations.

OAIC and Regulator Engagement

Included in Enterprise

Support If the OAIC Comes Calling

If the OAIC contacts you for a compliance check or a complaint, we help you prepare and attend meetings.

Included

Review of 2 draft responses per year. A 60-minute prep call per event.

Frequency

As needed, up to 2 events per year.

CAPS

2 events. Formal representation at a hearing is separate.

Out of scope

Defending against enforcement action or penalties.

Click Legal Portal

All plans

Full access to our Click Legal Portal. This is our legal and compliance library of over 300 templates, checklists and guides, plus training material.

Compass by Click Legal

All plans

Our monthly regulatory intelligence publication, for regulated financial services businesses. Each edition covers key legal and regulatory developments, with practical next steps.

Minimum Term: 6 Months

All plans

Legacy Items and Remediation

Not included in any plan

Always Out of Scope

Legacy items and remediation plans sit outside every plan. This includes historical issues and clearing a backlog.

Out of scope

Legacy privacy issues, remediation plans, and remediation project work. Quoted separately, once we understand the scope.

Our plans are flexible

Featured By Digital Reference (2025)

“Best Fractional General Counsel Services In Australia”

Featuring Click Legal founder, Hannah Deuk, as a “Founder To Watch In 2025”.

What Our Clients Say About Working With Us

“Hannah demonstrated exceptional leadership and regulatory expertise. She played a pivotal role in developing the control room and establishing a strong regulatory compliance framework…Beyond her deep technical knowledge, Hannah is an outstanding mentor, approachable, and insightful.”

“Hannah blends rare regulatory expertise with sharp business acumen. As her Manager at Barclays, I watched her master APRA/ASIC frameworks and turn them into clear, actionable strategies… She’s the kind of professional who simplifies complexity, and her integrity is unmatched.”

“Hannah has exceptional depth of knowledge and expertise in building robust legal, risk, and compliance frameworks….. Beyond her technical expertise, Hannah is a strategic thinker and a genuinely kind, friendly person who always supports and helps others.”

“Could not recommend Click Legal more highly! Must have for start ups and small business owners looking to trust someone to help set up your business right!”

“At IT Pro Tech, we partner with businesses who share our commitment to integrity. Click Legal stands out in the legal space for exactly that. Hannah and the team impressed us with their deep understanding of compliance-heavy sectors and their ability to offer clear, practical legal advice without overcomplicating the process.”

“Hannah at Click Legal has supported the board in establishing our documentation and legal framework to start on a solid footing. We appreciate her authentic interest in the charity’s mission… We appreciate how she explains complex concepts in simple terms, avoiding legal jargon.”

“Hannah and Click Legal have provided reliable legal advice to us. It has been integral in helping us meet all our AFSL obligations with confidence. I highly recommend their services to any business needing compliance support.”

“A fantastic team, very easy to work with and provide great service and advice. Hannah and her team are absolute superstars – commercial, knowledgeable and efficient.”

“Handled the legal admin we avoided—contracts, policies, the lot—so we could focus on growing the business.”

“After experiencing poor advice from other lawyers, I was fortunate to connect with Hannah. She stands out with her expertise, intelligence, and entrepreneurial mindset. Hannah’s ability to navigate complex legal matters and provide actionable guidance for startups and scaling businesses is unmatched. Highly recommend her services.”

“As a freelancer, I needed a solid contract to protect my work and clarify terms with clients. Click Legal’s templates were a lifesaver—easy to use, legally sound, and written in plain English. Having a professionally drafted agreement gave me confidence and saved me from potential disputes. …

“As a technology executive who has built products, led strategy, and advised startups, I know how critical it is to have legal counsel who actually understands the pace and complexity of early-stage ventures. Hannah Deuk and the team at Click Legal bring exactly that: pragmatic, founder-focused legal advice without the unnecessary friction. …

“Hannah’s expertise has been invaluable for Paragon, providing us with exceptional regulatory legal support that has strengthened our compliance framework and safeguarded our operations. She has expertly prepared and reviewed critical documents such as Product Disclosure Statements (PDS), …

“Hannah has provided invaluable legal support to PKF Corporate Finance over a number of years, particularly in relation to our AFSL obligations and AML/CTF compliance. She brings deep regulatory expertise, a clear and practical approach, and is always responsive and professional. …

“Startups, meet your legal dream team Click Legal. They speak your language, understand scaling businesses, and deliver founder-friendly advice that fits your growth.”

“Hannah has been a huge help to me and my business. I offer products, services, memberships and events and she has looked at all my offerings and provided me with new documentation that was needed to ensure my business is protected. She is so easy to work with and …

“Thank you for your incredible patience and dedication throughout this entire process. The level of care & attention to every detail has been truly outstanding, and Click Legal has been deeply responsive – even late at night & over weekends.”

Discuss Your Fractional Privacy Officer Needs

Our senior lawyers will contact you to discuss your privacy framework, data footprint & NDB/APP obligations & outline clear next steps.

How The Process Works

Step 1

Privacy Scope & Data Risk Review

We review what personal information you collect, how it flows through your systems & partners, & how your current Privacy Act/APP & NDB settings are structured.

Step 2

Framework, Policies & Data Map Design

We design or uplift your privacy framework – policies, notices, registers & data maps – so your obligations, data uses & high-risk processing are documented & governed.

Step 3

Onboarding As Your Privacy Officer

We step in as your Privacy Officer, access key systems, join relevant governance forums & agree how we’ll be involved in product, vendor & incident decision-making.

Step 4

Ongoing Privacy Operations & Incident Response

We review new initiatives, oversee higher-risk data uses, support contract/privacy reviews & coordinate breach/NDB responses so privacy is actively managed, not left to chance.

Step 5

Review & Adjust With Reforms & Growth

We adjust focus as Privacy Act reforms land, your products or jurisdictions change, or audits/breaches surface new issues, so your privacy framework stays aligned with reality.

In Financial Services & AML/CTF Law

0 + Years

AUSTRAC‑Regulated Businesses

0 + Sectors

Scope & Pricing Agreed Upfront

0 % Fixed-Fee

Why Choose Click Legal As Your Fractional Privacy Officer

Privacy Expertise For Regulated & Data-Heavy Businesses

We specialise in privacy for regulated, data-intensive organisations – lenders, wealth platforms, payments, fintech & digital asset businesses – not generic consumer sites.

Product-Aware, Practical Privacy

We work with product, engineering & operations to build privacy into roadmaps in a way that protects users & satisfies regulators, without endlessly blocking releases.

Senior Privacy Leadership Without Full-Time Overhead

You access senior Privacy Officer capability on a fixed-fee, fractional basis, avoiding the salary, bonus & HR overhead of hiring a full-time privacy executive.

Integrated With AML, AFSL & Governance

We already support AFSL/ACL compliance, AML/CTF & board reporting, so privacy plugs into your existing risk & governance structures instead of sitting in a separate silo.

Meet Your Legal Team

Hannah Deuk

Principal Lawyer & Founder, Sydney

Dominic Shaw

Lawyer, Sydney

Amira Hamit

Lawyer, Melbourne

Robert Williams

Lawyer, Melbourne

Jess Stolberg

Paralegal

Discuss Your Fractional Privacy Officer Needs

Our senior lawyers will contact you to discuss your privacy framework, data footprint & NDB/APP obligations & outline clear next steps.

How Fractional Privacy Officer Support Works

Fractional vs In-House Privacy Officer

A full-time Privacy Officer adds permanent salary, bonus & HR overhead. A fractional model gives you senior privacy leadership on a fixed-fee basis, sized to your current data footprint & risk.

When To Appoint A Fractional Privacy Officer

Once you hold significant customer or investor data, face Privacy Act/NDB questions or see “near misses”, leaving privacy spread across legal, IT & product becomes risky. We step in when your exposure is real but no one senior clearly owns it.

Privacy By Design vs Last-Minute Fixes

If privacy is only checked at the end of a build, it forces rework, delay & friction. A fractional Privacy Officer helps build privacy into product, data & vendor decisions early so you ship faster without unwanted surprises.

Framework, Evidence & NDB/OAIC Expectations

Regulators care about more than a website policy – they look for frameworks, DPIAs, data maps & how you handle breaches & notifications. We connect policies, registers & incident response into a story your board & OAIC can follow.

Compliance & Regulatory Insights

Common AFSL Variation Triggers: A Detailed Guide for AFS Licensees

AFSL Variation, ASIC Notification or New Licence: Which One is Right for You?

Non-Cash Payment (NCP) Facilities: A Complete AFSL Guide for Australian Fintech & Payment Platforms

Responsible Manager Changes and AFSL Variations: When a Key Person Change Triggers Action

Operating Outside Your AFSL: Risks and How an AFSL Variation Can Help

How to Operate as a Corporate Authorised Representative Under an AFSL

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Ready-to-Use Legal & Compliance Templates

Lawyer‑drafted legal templates in downloadable Word format.

Property Management Policy Template (Australia)

For Australian responsible entities and fund managers

$399.00 +GST

Free Download for COMPASS Members

Consultancy Agreement (Pro-Supplier) Template (Australia)

For Australian consultants supplying business services

$39.00 +GST

Free Download for COMPASS Members

Contractor Agreement Template (Australia)

For Australian businesses engaging independent contractors

$39.00 +GST

Free Download for COMPASS Members

Business Advisor Agreement Template (Australia)

For Australian companies engaging business advisors

$39.00 +GST

Free Download for COMPASS Members

Workplace Grievance Policy Template (Australia)

$35.00 +GST

Free Download for COMPASS Members

Right to Disconnect Policy Template (Australia)

$59.00 +GST

Free Download for COMPASS Members

Frequently Asked Questions

What is a Fractional Privacy Officer?

A Fractional Privacy Officer is a senior privacy lead who owns your privacy framework & NDB response on a part-time, subscription basis instead of as a full-time employee.

How is this different from a privacy consultant or general lawyer?

Consultants & lawyers usually advise on specific projects; a fractional Privacy Officer is your ongoing named owner for privacy decisions, plugged into governance, product & incident workflows.

Can you be recognised as our Privacy Officer?

Yes – subject to scope & engagement terms, we can be formally recognised as your Privacy Officer/privacy lead, work directly with management & boards, & be the point person on privacy matters, while the entity remains ultimately responsible.

How does the subscription model work?

We agree a fixed monthly fee based on a defined privacy scope – framework & policies, data mapping/DPIAs, vendor & cross-border reviews, incident/NDB response & training/reporting – reviewed as your products & risk evolve.

Do you replace our in-house legal/compliance or work alongside them?

For smaller organisations we can be the primary privacy function; for larger ones we work alongside in-house legal, compliance & IT, owning privacy decisions while internal teams handle day-to-day execution.

Who do you usually act for as Privacy Officer?

We typically act for APP entities & data-heavy businesses in & around financial services – lenders, wealth & investment platforms, payments & remittance providers, fintechs & digital asset platforms – & can scope other regulated/data-heavy businesses case by case.

What happens if we suffer a data breach or NDB-level incident?

We help triage the incident, assess serious harm, decide if NDB notification is required, manage OAIC & customer communications, & feed lessons back into your controls & training so the risk reduces over time.

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