Fractional Privacy Officer Services

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.

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. 

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.

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.

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 in Our FGC Plans

Our Fractional Privacy Officer role is usually delivered as part of our Fractional General Counsel subscription, often alongside Compliance Officer & AML/CTF officer support. The plans below show typical tiers; we confirm the right tier & privacy scope based on your data footprint, APP/CDR obligations, jurisdictions & breach/incident profile.

Inclusions

Basic

Standard

Enhanced

Premium

Enterprise

$2,000/mo. +GST

$4,000/mo. +GST

$6,000/mo. +GST

$8,000/mo. +GST

$10,000/mo. +GST

Core legal & compliance documents tailored to your business

Hands‑on implementation support (onsite or online)

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Compliance registers and templates

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Compliance reporting support

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Standard staff training

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Annual review of documents and frameworks

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Quarterly compliance updates

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Monthly strategy or consultation session

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Tailored training for staff

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Regulator & industry update briefings

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Dedicated support line for ad‑hoc advice

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Additional legal & compliance documentation

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Ongoing strategic legal advisory & consultation

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Remediation support & project work

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Regulator engagement assistance

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Full Inclusions & Plan Limits: View the full inclusions, frequency, limits and minimum term for each plan in our Fractional General Counsel – Inclusions & Key Limits table here.

Terms: Prices are per month, exclusive of GST. At checkout, Stripe will display the GST‑inclusive total (for example, $10,000 + GST = $11,000 per month). These online prices are for small to medium businesses that fit the assumptions and limits in the spec sheet. If your business is larger, more complex or you’d like a tailored quote, please contact us before purchasing. If, after purchase, we determine that your business is outside scope, we may offer a revised custom quote or a full refund before work begins. A minimum initial term of six (6) months applies to all Fractional General Counsel plans. Your engagement is governed by our Terms & Conditions of Engagement.

Full Inclusions & Plan Limits: View the full inclusions, frequency, limits and minimum term for each plan in our Fractional General Counsel – Inclusions & Key Limits table here.

Terms: Prices are per month, exclusive of GST. At checkout, Stripe will display the GST‑inclusive total (for example, $10,000 + GST = $11,000 per month). These online prices are for small to medium businesses that fit the assumptions and limits in the spec sheet. If your business is larger, more complex or you’d like a tailored quote, please contact us before purchasing. If, after purchase, we determine that your business is outside scope, we may offer a revised custom quote or a full refund before work begins. A minimum initial term of six (6) months applies to all Fractional General Counsel plans. Your engagement is governed by our Terms & Conditions of Engagement.

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”.

Award graphic: "Best Fractional General Counsel Services in Australia 2025" with a 5-star rating.

What Our Clients Say About Working With Us

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

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

Ready-to-Use Legal & Compliance Templates

Lawyer‑drafted legal templates in downloadable Word format.

Frequently Asked Questions

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.

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.

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.

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.

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. 

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.

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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