Avid Certification Services Limited (UK Company Number 14865982), KJR (KJ Ross & Associates PTY LTD); ACT & NSW, AU, and other providers (together, the Age Assurance Technology Trial (AATT) Providers) and their related and associated bodies corporate (us, we, our) maintain a policy of strict confidence concerning your (you, your) personal information (Privacy Policy).
The AATT Providers have been appointed to test a range of age assurance solutions, including age analysis, artificial intelligence (AI) based estimation, parental consent/control, and identity document verification. This Site has been established for the purpose of the AATT.
This Privacy Policy has been developed in accordance with the Privacy Act 1988 (Cth) (Privacy Act). The Privacy Policy applies to the collection, storage, use and disclosure by us of your personal information in relation to the AATT. This Privacy Policy applies to information provided to us whether via https://ageassurance.com.au/ (Site) or any other means and sets out how we will comply with the Australian Privacy Principles under the Privacy Act. It also applies to age assurance providers participating in the AATT, who have agreed to abide by this Privacy Policy as a condition of their participation.
Although we will comply with this Privacy Policy in respect of information provided to us by persons under the age of 18 years, those persons must obtain the consent of a parent or guardian prior to using the Site and the parent or guardian will be responsible for appropriately supervising the person’s use of the Site.
If you have any further questions or if you wish to receive more information on our information practices and Privacy Policy, please contact our Privacy Officer at [email protected]; Unit 321B Broadstone Mill, Broadstone Road, Stockport, SK5 7DL, UK.
Types of personal information collected
The types of personal information we collect will depend on the age assurance solution being tested to verify your age and how you are participating in the AATT.
In respect of all technologies that we test, we will collect your date of birth as a month and year. We will also collect this data for the purpose of recruiting you to participate in the Trial. We will collect other personal information from you according to the kinds of age assurance technology we are testing. The types of information we collect, and the purposes for which we are collecting it, include but are not necessarily limited to:
| Type of information | Purpose |
| Date of Birth as a month and year | To check if the technology accurately determines a user’s age. |
| Gender | To assess performance differences across genders. |
| Skin Tone | To evaluate whether technology works equally well across different skin tones. |
| Ethnicity | To check for any unintended impacts based on ethnicity. |
| Type | Purpose |
| Face Image | To test age estimation systems that analyse facial features. |
| Face Videos | To test age estimation systems that analyse facial features. |
| Voice Recordings | To test age estimation systems that analyse voice characteristics. |
| Hand Gesture Video | To test age assurance systems that analyse hand dexterity and movement. |
| Typing Pattern | To test age assurance systems based on typing behaviour. |
| Type | Purpose |
| Device Make | To ensure technologies work across different devices. |
| Sensor Quality | To test if sensor quality affects accuracy. |
| Wearing Attributes (e.g., glasses) | To test whether worn items impact accuracy. |
| Network Conditions | To test if internet speed affects performance. |
| Image Lighting | To evaluate how lighting impacts face recognition. |
| Audio Quality | To test if background noise affects voice-based age estimation. |
| Type | Purpose |
| Bank Name | To check if online banking checks accurately verify age. |
| Email ID | To test whether age can be inferred from email records. |
| Marriage Certificate | To check if government documents can verify age. |
| Income Tax Certificate | To assess the use of official records for age verification. |
| Attributes from Personal ID (e.g., Passport, Driver’s Licence) | To verify identity as part of age checks. |
If it is reasonable and practical to do so, we will collect personal information directly from you. This will take place when you interact with our Site or otherwise interact with us regarding your participation in the AATT.
Sensitive information
We will not collect any sensitive information from you revealing your political opinions, religious or philosophical beliefs, or trade union memberships. However, we will collect sensitive information that includes biometric information where we are testing age assurance technology that involves the use of biometric data to verify age such as facial or voice-based age estimation technology. Where we are testing the effectiveness of such technologies we may also collect details as to your ethnic origin, race or any disability to ensure that the age assurance solutions are inclusive and accommodate these individual differences.
How we collect this information
As we are testing a range of age assurance solutions, the ways we collect your personal information will include the following:
We will not collect personal information unless the information is reasonably necessary for or directly related to one or more of our functions or activities. If we are unable to collect the personal information we reasonably require we may not be able to facilitate your participation in the AATT. Your participation is voluntary at all times.
We may also collect personal information from third parties such as the subcontractors engaged to deliver the AATT or from publicly available sources of information. All personal information that we collect is reasonably necessary for the purposes relating to the provision of the AATT and testing a range of age assurance solutions as outlined above.
Unsolicited information
If we are provided with personal information about you that we did not ask for and we determine that we could have collected this information from you had we asked for it, we will notify you as soon as practicable. This notice will be given unless to do so would be in breach of an obligation of confidence. If we could not have collected this personal information, we will lawfully de identify or destroy that personal information.
Use and disclosure of information
We may use personal information about you for the primary purpose of facilitating the AATT and for other purposes for which you would reasonably expect us to use that information, including to search for participants, facilitate your participation in the AATT, test the various age assurance solutions (including by disclosing your personal information to participating age assurance providers), evaluate findings and produce reports and recommendations on the findings of the AATT. Wherever practicable, your data will be anonymised and a data minimalist approach will be adopted. Your data is also collected for the purposes of improving the functionality of the Site.
In order to deliver the AATT, we may disclose your personal information to other organisations that also engaged to deliver the Trial such as data science experts, legal providers, independent evaluation experts, design and visualisation experts, and subject matter experts in the areas of age assurance, industry engagement, safety regulation, ethics and data. A list of the subcontractors engaged on the AATT can be found at https://ageassurance.com.au/project-team/. We take reasonable steps to ensure that these organisations are bound by privacy obligations in relation to the protection of your personal information.
We may provide certain information about you including your personal information to our related bodies corporate.
When you visit the Site the server may attach a “cookie” to your computer’s memory. A “cookie” assists us to track and store information about your usage of the Site and the pages that may be of most interest to you.
We may use cookies from time to time to:
Our Site creates a personal record of your use of the Site, links the information collected through cookies to any personal information you provide and may be used to identify you.
If you choose, you should be able to configure your computer so that it disables “cookies” or does not accept them. However, please note by disabling cookies, your user experience may be affected and you might not be able to take advantage of certain functions of the Site.
We do not intend to use your personal data for direct marketing.
We take all reasonable steps to ensure that your personal information held by us is accurate, up-to-date, complete, relevant and not misleading. If you believe that any of your personal information is not accurate, up-to-date, complete, relevant and not misleading, please contact us (see below) and we will take all reasonable steps to correct it within a reasonable time.
We are a resident company of the United Kingdom. Your personal information overseas may also be transferred to certain service providers for the purposes of the AATT and we have contractual mechanisms in place with them to protect your personal information. Those providers include:
All of the above providers are also situated in the United Kingdom.
By your use of the Site or your participation in the AATT you consent to the collection, storage, use and disclosure of your personal information in accordance with this Privacy Policy and as otherwise permitted under the Privacy Act.
We will use all reasonable endeavours to keep your personal information in a secure environment, however, this security cannot be guaranteed. The AATT providers use privacy-preserving systems wherever possible. If we are storing your information it will be assigned a unique code, which may include a suffix indicating the specific type of information being collected. For example, identifiers may be structured as AATT0333_Name, AATT001_Passport, or AATT1234_PhoneNumber. This approach pseudonymises information while maintaining traceability for validation purposes. These security measures are designed to ensure your personal information is not subject to unauthorised access, loss or misuse. If you reasonably believe that there has been unauthorised use or disclosure of your personal information, please contact us (see below).
If we no longer need your personal information, unless we are required under Australian law or a court or tribunal order to retain it, we will take reasonable steps to destroy or de-identify your personal information in accordance with our document and information retention policy. To the extent possible, your data will be securely destroyed or de-identified upon the conclusion of the AATT.
Despite the reasonable steps taken to keep information secure, breaches may occur. In the event of a security incident, we have in place procedures to promptly investigate the incident and determine if there has been a data breach involving personal information, and if so, to assess if it is a breach that would require notification. If it is, we will notify affected parties in accordance with Privacy Act requirements.
We may vary the terms of this Privacy Policy at any time. You should check this Privacy Policy regularly so that you are aware of any variations made to this Privacy Policy.
If you request access to the personal information we hold about you, we will respond to your request within a reasonable period of time and, where reasonable and practicable, give access to the information in the manner you request. This will be subject to any exemptions allowed under the Privacy Act. You may request this information by sending an email to us at [email protected]
We may charge a reasonable fee for providing that information where this is provided for under the Privacy Act.
When contacting us you have the option to either not identify yourself or to use a pseudonym. However, this will not apply if it is impracticable for us to communicate with you that way or we are required or authorised under Australian law (or a court or tribunal order) to only deal with individuals who have identified themselves.
