APP 9: adoption, use or disclosure of government related identifiers
An organisation must not adopt a government identifier (e.g. Medicare or tax file number) as its own ID for a person. It should use its own customer ID, with limited exceptions.
Understanding APP 9: adoption, use or disclosure of government related identifiers in VCE Software Development U3O2
What it does: Generating a new internal ID means the system does not rely on a tax file number to identify the person. The condition shows the identifier is used only when an exception applies, rather than as a normal identifier for the person. APP 9 stops organisations adopting a government related identifier as their own ID. An internal ID like GYM-1042 is the compliant choice. Using a Medicare number as the primary key adopts a government identifier as the organisation's own ID, which APP 9 restricts. Use a generated customerId instead. APP 9 is a restriction with limited exceptions, for example where the use is required or authorised by law. It is not a free-for-all.
Common mistakes: The clinic is adopting the Medicare number as its own customer ID, which APP 9 restricts. It should create its own ID with customerId ← newCustomerId(). The tax file number is being used as the record key, so it has become the organisation's identifier for the person. The key should be the organisation's own generated id.
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