OAIC 2026 Enforcement Sweep — Active Now: 60 organisations across six sectors under compliance review. Penalties up to AUD $66,000 per infringement. Automated decision-making disclosures mandatory December 2026.

Is your organisation ready? →

End-to-End Data Sovereignty

Compliance.
Infrastructure.
Certainty.

sovSure is Australia's end-to-end data sovereignty firm. We assess your obligations, migrate your data onto sovereign infrastructure, implement your compliance framework, deploy your private AI — and maintain it all, ongoing. One firm. No gaps. No handoffs.

We practise what we advise. sovSure operates exclusively on sovereign Australian infrastructure. No US cloud. No third-party data processors. Every system we build for clients is built to the same standard we hold ourselves to.

The Gap Most Firms Miss

A compliance report is not compliance.

Knowing you are in breach of the Privacy Act 1988 does not fix the breach. sovSure identifies every obligation — then builds the infrastructure, policies, and systems that meet them. In one engagement. With one firm responsible for the outcome.

Australian & European Law

Dual-jurisdiction expertise — genuinely held.

Few Australian advisory firms hold working knowledge of both the APP framework and GDPR (EU) 2016/679. sovSure operates across both, for organisations that handle Australian and EU personal data simultaneously.

Sovereign AI

AI that never leaves your jurisdiction.

Every time your organisation sends a query to a US AI provider, you are disclosing that information to a foreign company under foreign law. sovSure deploys private AI agents on Australian servers — zero US processing, zero exposure.

Aligned with
OAIC Regulatory Standards Privacy Act 1988 (Cth) incl. 2024 Amendments GDPR (EU) 2016/679 NAIC Guidance for AI Adoption 2025 Australian Government PSPF APRA CPS 234 ISO/IEC 27001 Austrade Export Compliance DISP

Active Enforcement — 2026

The OAIC is already inside the room.

In January 2026, the Office of the Australian Information Commissioner launched Australia's first-ever proactive compliance sweep — targeting approximately 60 organisations across six sectors identified as high-risk for over-collection of personal information in person. This is not a warning of future action. It is active enforcement, now.

The sweep assesses compliance with Australian Privacy Principle 1.4 — the requirement to maintain a transparent, accurate, and compliant privacy policy. Non-compliant organisations face infringement notices and penalties of up to AUD $66,000 per infringement, with civil penalties escalating to AUD $50 million for serious or persistent breaches.

The OAIC has also signalled continued focus through 2026 on facial recognition, biometric data, and automated decision-making, following landmark enforcement determinations against Bunnings Group (2024) and Kmart Australia (2025). New disclosure obligations for automated decision-making under amended APPs 1.7–1.9 take effect December 2026.

Licensed venues — ID collection at entry
Pharmacies and chemists — ID and health information
Real estate agents — personal data at open inspections
Car rental companies — identity and payment data
Car dealerships — personal information for test drives
Retail and hospitality — loyalty programmes, in-person collection, biometrics
Broader enforcement applies to all APP entities — your sector may be next
Request an urgent compliance review →

$50M

Maximum civil penalty under the Privacy and Other Legislation Amendment Act 2024 — the greater of AUD $50 million, 3× the benefit obtained, or 30% of adjusted annual turnover.

$66K

Per-infringement penalty for failure to maintain a compliant privacy policy — the minimum enforcement tool now available to the OAIC without a formal investigation.

Dec '26

Automated decision-making disclosure obligations come into force under amended APPs 1.7–1.9. Any organisation using AI or automated systems that significantly affect individuals must disclose this in their privacy policy.

10 Jun '25

Australia's statutory privacy tort in force. Individuals can now sue for serious invasions of privacy without proving financial damage. Emotional distress alone is sufficient grounds.

Your data is almost certainly
stored in breach of Australian law.

Most Australian organisations — including large, sophisticated ones — are storing personal information on infrastructure that directly violates the Privacy Act 1988 (Cth) and, where EU clients are involved, the GDPR.

AWS, Microsoft Azure, Google Cloud, Gmail, Microsoft 365, Slack, and the majority of US-headquartered SaaS platforms store and process data subject to US jurisdiction — including the CLOUD Act 2018, which grants US authorities access to data held by American companies regardless of where servers are physically located.

Australian Privacy Principle 8 requires that before transferring personal information overseas, an organisation must take reasonable steps to ensure the recipient will handle it in accordance with the APPs. No major US cloud provider satisfies this requirement by default. The GDPR imposes equivalent restrictions on transfers outside the EEA without adequate safeguards.

This is not theoretical. The OAIC is actively enforcing cross-border transfer obligations, and the 2024 amendments have expanded its enforcement toolkit significantly. Choosing the "Australian data centre" option from a US provider does not solve this problem — if the company is subject to US jurisdiction, so is your data.

Breach
AWS / Azure / Google Cloud — US-jurisdiction cloud storage of Australian personal information without adequate APP 8 safeguards or GDPR Chapter V transfer mechanisms. "Australian data centres" do not resolve this.
Breach
Gmail / Microsoft 365 — Business email containing personal information processed on US-controlled infrastructure. Metadata scanning by providers creates additional disclosure exposure.
Breach
US-based AI tools — Sending employee queries, client data, or internal documents to ChatGPT, Copilot, Gemini, or any US-hosted AI constitutes an overseas disclosure of potentially sensitive information under APP 8.
Breach
Offshore outsourcing — Customer service, data entry, or any function involving personal information handled by overseas contractors without compliant data processing agreements in place.
Breach
Third-party analytics and CRM — Platforms exporting behavioural or personal data to US-headquartered vendors without adequate disclosure, consent, or contractual protections.
Risk
Biometric and facial recognition data — Any deployment of FRT, fingerprint scanning, or biometric authentication without explicit informed consent, a written governance policy, and compliant data handling. Active OAIC enforcement focus in 2025–2026.

End-to-end means the problem
is solved. Not reported.

Other compliance firms give you a document. sovSure gives you a compliant organisation — with the infrastructure, systems, and ongoing management to stay that way.

01 — Assess

We identify every breach, obligation, and gap across your entire operation.

Full audit of your data flows, storage infrastructure, vendor relationships, privacy policies, staff practices, and AI usage. Mapped against the APPs, GDPR, PSPF, and any sector-specific frameworks that apply. You receive a complete picture of your exposure — every gap prioritised by legal risk and urgency.

02 — Migrate

We move your data off non-compliant US infrastructure and onto sovereign Australian servers.

sovSure manages the full migration of your data, email, document storage, and operational systems from US-jurisdiction providers to sovereign Australian infrastructure. We handle the technical transition, vendor contract exits, and continuity planning. Your operations do not pause.

03 — Implement

We build and install the policies, systems, and governance your organisation needs to stay compliant.

Privacy policies, data handling procedures, breach response protocols, vendor agreements, staff training, AI governance frameworks, and board reporting — all drafted and implemented by sovSure. Not recommendations for you to action. Completed, operational deliverables from day one.

04 — Maintain

We operate your sovereign infrastructure on an ongoing basis — so you never chase another vendor.

sovSure provides ongoing managed hosting on private, sovereign Australian servers — including email, document storage, and AI agents. One firm. Complete accountability. Regulatory monitoring included, so your compliance posture evolves with the law — proactively, not reactively.

The full stack.
Under one roof.

sovSure is a single point of accountability for your entire data sovereignty posture — from the first regulatory gap through to compliant infrastructure and ongoing hosting. No referrals to third-party IT providers. No compliance report that leaves you to figure out implementation. One engagement. One firm. The outcome delivered.

01

Compliance Advisory

Regulatory assessment, documentation, and legal defensibility.

Diagnostic

Privacy & Sovereignty Audit

Full gap analysis across the Australian Privacy Principles, GDPR, PSPF, and sector-specific obligations. Maps every data flow, storage location, and vendor relationship against your actual legal exposure. Produces a prioritised remediation roadmap — specific, actionable, and legally grounded.

APP 1–13GDPR Ch. IIPSPFOAIC Aligned

Documentation

Policy & Procedure Drafting

Privacy policies, data handling procedures, breach response plans, vendor data processing agreements, AI usage disclosures, and automated decision-making governance. Drafted for legal defensibility and operational use — written so staff can follow them, not just lawyers can read them.

Privacy PolicyDPA TemplatesBreach ProtocolAI Disclosure

Training

Staff & Executive Training

Role-specific privacy training across operational staff, technical teams, and executive leadership. Satisfies OAIC expectations of ongoing organisational privacy culture. Board briefings on regulatory exposure, fiduciary obligations under the 2024 amendments, and AI governance responsibilities.

OAIC GuidanceExecutive BriefingAll StaffAI Governance
02

Sovereign Infrastructure

Migration, hosting, and ongoing sovereign operations — fully managed.

Migration

Cloud & Email Sovereignty Migration

Full managed transition from US-jurisdiction cloud and email platforms to sovereign Australian infrastructure. sovSure handles the entire migration — data transfer, system configuration, vendor contract exits, staff transition to new platforms, and continuity planning. You remain operational throughout. We do not hand you instructions. We do the work.

AWS ExitEmail MigrationDocument StorageZero Downtime

Hosting

Managed Sovereign Hosting

Ongoing hosting of your email, document storage, operational systems, and AI agents on private Australian servers — managed by sovSure. Data never leaves Australian jurisdiction. No US vendors in the chain. Single accountable provider with full audit logging, security monitoring, and regulatory alignment included.

Private ServerAU JurisdictionManagedAudit Logging

Cross-Border

EU–AU Cross-Border Compliance

For Australian organisations receiving EU personal data or operating with EU-based clients. Standard Contractual Clauses, adequacy assessments, Data Protection Officer obligations under GDPR Article 37, binding corporate rules, and dual-framework harmonisation across APP and GDPR simultaneously.

SCCsBCRsDPOAdequacy Review
03

Sovereign AI

Private, compliant AI agents on Australian infrastructure — configured by your policies, inaccessible to all third parties.

Deployment

Private Sovereign AI Agent Setup

sovSure deploys AI agents on private servers within Australian jurisdiction — accessible only to your organisation. No data is processed by US AI providers. No queries leave your sovereign environment. We configure the AI with your internal policies, procedures, and regulatory obligations from day one — so every response is governed by your rules, not generic model defaults.

Private ServerPolicy-GovernedOAIC CompliantNo US Processing

Governance

AI Compliance & Governance Programme

Full preparation for the December 2026 automated decision-making disclosure requirements under new APPs 1.7–1.9. AI usage audit, privacy policy amendments, staff governance framework, and alignment with the NAIC Guidance for AI Adoption (October 2025). Government clients: APS AI Plan and DTA Policy v2.0 (December 2025) alignment included.

APP 1.7–1.9NAIC AI6APS AI PlanDec 2026 Ready
04

Ongoing Advisory

Retainer relationships for continuous compliance oversight as your organisation and the law evolve.

Retainer

Regulatory Monitoring & Incident Response

Monthly or quarterly retainer providing responsive advice on regulatory developments, incident response, and compliance maintenance. Includes monitoring of OAIC enforcement actions, EDPB decisions, Privacy Act amendments, and AI regulatory developments relevant to your sector. You are informed before changes require action.

Regulatory WatchIncident ResponseBoard Reporting

By Design

Privacy & Sovereignty by Design

For organisations building new systems, entering new markets, or expanding data operations. sovSure advises at the design stage — before architecture is set — so that privacy is built in from the start, not retrofitted at cost. Aligns with the OAIC's endorsed principle of Privacy by Design and the secure-by-design standard sovSure applies across all its own operations.

Privacy by DesignSecure by DesignNew Systems

From AWS to Australian soil.
Managed end-to-end by sovSure.

If your organisation runs on Gmail, AWS, Dropbox, Slack, or any US-headquartered platform — your data is subject to US law, regardless of where the physical servers are located. sovSure fixes this end-to-end, without requiring you to hire a technical team, manage a second vendor, or pause operations.

Why "Australian Data Centre" Options Don't Solve the Problem

The US CLOUD Act 2018 overrides physical server location entirely.

Under the Clarifying Lawful Overseas Use of Data Act (CLOUD Act 2018), US authorities can compel American technology companies to produce data stored anywhere in the world — including servers physically located in Australia. AWS, Microsoft Azure, Google Cloud, and virtually all major US SaaS providers are subject to this law. Selecting the "Australian region" in AWS does not remove your data from US legal jurisdiction. If the company holding your data is an American company, that data is reachable by US government authority — creating a direct breach of APP 8 and incompatibility with GDPR Chapter V. The only solution is infrastructure that is not subject to US jurisdiction at all.

Phase 01 — Audit

Full infrastructure and data flow mapping

sovSure maps every system that touches personal information — cloud storage, email, CRM, analytics, AI tools, payment processing, and third-party integrations. Each is assessed for sovereignty compliance and cross-border exposure under APP 8 and GDPR Chapter V.

Phase 02 — Architecture

Sovereign infrastructure design

We design your compliant infrastructure configuration — sovereign email, document management, operational storage, and AI agents. Scoped to your operational complexity. No generic template; every architecture is specific to your organisation's data flows and risk profile.

Phase 03 — Migration

Managed transition with zero operational downtime

sovSure manages the full technical migration — data transfer, system configuration, staff onboarding, vendor contract exits, and continuity testing. Your operations continue without interruption. We do not hand you a migration guide. We execute it.

Phase 04 — Documentation

Compliance documentation updated to reflect your new posture

Following migration, sovSure updates all relevant compliance documentation — privacy policies, vendor agreements, data maps, breach response protocols, and AI governance frameworks — to reflect your new sovereign infrastructure accurately.

Phase 05 — Hosting

Ongoing managed sovereign hosting

Post-migration, sovSure operates your sovereign infrastructure on a managed basis. One accountable provider for cloud, email, AI, and compliance advisory. Regular security reviews. No need to manage a separate IT firm, cloud provider, and compliance advisor simultaneously.

Phase 06 — Forward Compliance

Proactive alignment as regulation advances

Data sovereignty regulation is accelerating. sovSure monitors all relevant legislative and regulatory developments — OAIC enforcement actions, EDPB guidance, Privacy Act amendments, and AI governance updates — and proactively updates your infrastructure and documentation. You are always ahead of the compliance horizon.

AI that never leaves
your jurisdiction — or your control.

Every query sent to a US-hosted AI is a disclosure of that information to a foreign company operating under foreign law. For health, legal, financial, government, and defence organisations, this is not a grey area. It is a breach.

sovSure builds and deploys private AI agents on servers hosted within Australian jurisdiction — servers that no external party, including sovSure, can access without your explicit authorisation. Your data never traverses a US network. Your queries never train a third-party model.

We configure each AI agent with your organisation's internal policies, procedures, regulatory obligations, and operational context. Every response is already framed by your governance — not generic output that requires human compliance review before it can be used.

For organisations where sending any internal information to a US AI provider creates immediate legal exposure, sovereign AI is not a premium option. It is the only compliant option.

sovSure is developing proprietary in-house agentic AI capability — purpose-built for sovereign deployment, with no dependency on US model providers. This will be available to clients as a fully managed service: deployed on your private infrastructure, configured to your specific operational and regulatory requirements, and maintained by sovSure as your compliance posture and operational needs evolve.

Australian AI Regulatory Timeline — Key Dates
Oct 2024
OAIC releases dual AI guidance — for businesses using AI products, and for developers training generative AI models. Sets clear expectations for APP compliance in AI contexts including consent, secondary purpose, and sensitive information.
Jun 2025
Privacy tort in force — Individuals can now sue for serious invasions of privacy without proving financial damage. AI systems that expose personal information create direct litigation risk for organisations.
Oct 2025
NAIC Guidance for AI Adoption (AI6) — Six essential practices replace the Voluntary AI Safety Standard as the primary government reference for responsible AI governance in Australia.
Dec 2025
APS AI Policy v2.0 — All Commonwealth entities must develop strategic AI adoption plans with designated accountability for AI use cases. Mandatory requirements, not voluntary guidance.
Early 2026
Australian AI Safety Institute becomes operational — Independent technical monitoring, risk assessment of advanced AI systems, and guidance on AI safety and risk for regulators and industry.
Dec 2026
Automated decision-making disclosure obligations — New APPs 1.7–1.9 require all organisations to disclose in their privacy policy how personal information is used in automated systems that significantly affect individuals. All AI users must be ready by this date.
01

Sovereign AI Agent Deployment

Private AI deployed on dedicated Australian servers accessible only to your organisation. Configured with your internal policies, regulatory obligations, and operational context from day one. No US processing. No data accessible to any external party.

Zero US Exposure
02

Policy-Governed Configuration

Your AI agent is not a generic tool. It is configured with your specific regulatory obligations, internal policies, privacy requirements, and approved use boundaries — so all output is governance-compliant by design, not by review after the fact.

Governance Built-In
03

Inaccessible Private Server

Your sovereign AI runs on a private server inaccessible to all third parties — including sovSure — without your authorisation. Full audit logging. No training of external models on your data. No data retention by any vendor anywhere in the chain.

True Privacy by Design
04

December 2026 Compliance Package

Full preparation for automated decision-making disclosure requirements under new APPs 1.7–1.9. AI usage register, privacy policy amendments, staff governance framework, and alignment with NAIC AI6. Delivered well ahead of the December 2026 compliance deadline.

Dec 2026 Ready
05

Managed Sovereign AI Hosting

Ongoing management of your private AI infrastructure — security updates, regulatory alignment as the OAIC issues new AI guidance, and capability expansion as your needs evolve. Included within sovSure's managed hosting service. One subscription. Full accountability.

Fully Managed

We hold ourselves
to the standard we set for clients.

sovSure does not advise on data sovereignty while outsourcing its own operations to non-sovereign infrastructure. Every system we use internally — email, document storage, AI, client communications — operates under the same sovereign, privacy-by-design standard we implement for clients. We are not a firm that writes compliance documents. We are a firm that lives compliance.

Principle 01

Secure by Design

Privacy and security protections are built into the architecture of every system — not added as a layer after deployment. The design intent is always the highest achievable standard, not the regulatory minimum.

Principle 02

Prevention Over Remediation

Data breaches, regulatory penalties, and compliance failures are preventable. sovSure works forward from the regulatory horizon, not backward from an incident. The most expensive compliance engagement is the one that happens after a breach.

Principle 03

Full Operational Sovereignty

sovSure does not use US-jurisdiction cloud, email, or AI providers for any internal operations. No client data, internal data, or operational data is handled by any vendor outside Australian privacy law jurisdiction. We do not ask clients to do what we do not do ourselves.

Principle 04

Technology Precedes Law

Legislation always lags the technology that makes it necessary. sovSure advises with an understanding of where regulation is heading — not just where it currently stands. Clients who engage us today are positioned for the compliance landscape of 2027 and beyond.

Principle 05

Privacy as a Fundamental Right

sovSure holds a core belief in the privacy rights of individuals, organisations, and nations. Compliance is not the ceiling of our ambition — it is the floor. The standard we work toward is the highest achievable protection, because that is what privacy actually means.

Principle 06

One Firm, Full Accountability

When you engage sovSure, one firm is accountable for your entire data sovereignty posture — from the first audit through to ongoing infrastructure hosting. No referrals. No handoffs to third-party IT providers. No compliance gaps between advisory and implementation.

Sectors

sovSure serves any Australian organisation with material data sovereignty obligations — across the private sector, regulated industries, and all levels of government.

Financial Services

ASX-listed entities, banks, super funds, and insurers under Privacy Act, APRA CPS 234, and cross-border EU client obligations.

Health & Life Sciences

Private hospitals, pathology, aged care, and health technology under sensitive information provisions, My Health Records Act 2012, and GDPR where EU patients are involved.

Government & Public Sector

Commonwealth and state agencies with PSPF obligations, APS AI Plan requirements, and heightened community expectations now enforceable under the 2024 amendments.

Legal & Professional Services

Law firms, accounting practices, and consultancies handling sensitive client data where professional confidentiality obligations intersect directly with privacy law requirements.

Technology & SaaS

Australian technology companies scaling into EU markets — requiring GDPR compliance alongside domestic APP obligations from the point of first EU market contact.

Defence & Critical Infrastructure

DISP-registered entities and organisations under the Security of Critical Infrastructure Act 2018 (Cth) with heightened sovereignty and security requirements.

Retail & Hospitality

Sectors under active OAIC enforcement in 2026 — loyalty programmes, in-person ID collection, facial recognition, and the overcollection of personal information in commercial settings.

Education & Research

Universities, research institutions, and EdTech handling student data, international data-sharing arrangements, and AI usage in learning and research environments.

Three clear pathways.

Whether you need to understand your exposure, resolve it entirely, or maintain compliance as an ongoing relationship — sovSure has a structured engagement model for your situation.

Pathway 01

Assessment

Fixed fee · Scoped per organisation

  • Full APP and/or GDPR gap analysis
  • Data flow and storage mapping
  • Vendor sovereignty assessment
  • AI usage and disclosure audit
  • Biometric and FRT exposure review
  • Prioritised remediation roadmap
  • Executive briefing on findings
Request Scope

Pathway 03

Retainer Advisory

Monthly · Continuous compliance relationship

  • Regulatory monitoring and alerts
  • Incident response guidance
  • Periodic compliance review
  • Infrastructure and policy maintenance
  • AI governance as regulation evolves
  • Board and executive reporting
  • Annual full-scope review
Request Scope

National presence. European reach.

sovSure is headquartered in Melbourne with active contacts in Sydney and Brisbane, a planned government and defence headquarters in Canberra, and cross-border advisory capability across Europe. Advisory engagements are delivered in person and remotely across all Australian jurisdictions.

Melbourne

● Headquarters

Primary operations, compliance advisory, and sovereign infrastructure management.

Canberra

○ Planned HQ

Future government and defence sector headquarters. Active contacts in the capital territory.

Sydney & Brisbane

● Active

Active business contacts. On-site advisory available by arrangement.

All Major Cities

● National

In-person attendance anywhere in Australia by arrangement. Willing to travel for the right engagements.

Europe

● By Arrangement

EU cross-border compliance advisory. In-person European engagements available by appointment.

Request an Assessment

Tell us about your organisation and where you are in your compliance journey. We respond within two business days with a clear proposal or a scoping call. Urgent matters — including OAIC notices — accommodated same day on request.

Headquarters

Melbourne, Victoria, Australia
Sovereign infrastructure operated nationally

National Presence

Melbourne · Canberra (planned) · Sydney · Brisbane
All major Australian cities by arrangement

Cross-Border Advisory

Australian and European data sovereignty
EU in-person engagements by arrangement

Response Time

Within two business days standard
Same-day response for urgent regulatory matters

Engagement Models

Fixed-fee assessment · Full sovereignty programme
Monthly retainer · Managed sovereign hosting