ISGA Response to Australian Privacy Reform Consultation
On behalf of members, the International Social Games Association (ISGA) has submitted a formal response to be considered as part of the Australian Government’s consultation on proposed reforms to Australia’s privacy laws.
Key points in the ISGA’s submission include:
The ISGA supports reforms that strengthen privacy, online safety, child protection, transparency and accountability, while maintaining a proportionate and risk-based framework.
Existing global privacy and data protection frameworks, including the EU General Data Protection Regulation (GDPR), should be recognised when assessing compliance with Australian obligations.
Requirements relating to algorithms and personalisation should focus on higher-risk automated decision-making without inadvertently capturing ordinary game features such as recommendations, difficulty balancing or reward personalisation.
Protections for children and vulnerable users should be supported by privacy-preserving age assurance and safety-by-design, with age assurance requirements proportionate to the different risk profiles of mobile games.
Any right to erasure should take account of legitimate data retention requirements, including records needed for player protection, self-exclusion, fraud prevention and regulatory compliance.
Data breach requirements should allow timely and phased notification, while recognising existing global incident response frameworks that meet established standards such as the GDPR.
Reforms relating to consent, advertising and personal information should distinguish harmful practices from ordinary operational activities such as advertising delivery, measurement and fraud prevention.
Australia’s reforms should work alongside established global compliance frameworks, helping to close genuine gaps while avoiding unnecessary duplication for internationally operating games companies.
Published October 2026