BSA filed comments to the Office of the Australian Information Commissioner’s (OAIC) on the OAIC’s proposed Guidance for Transparency in Automated Decision-Making (ADM). BSA encouraged the OAIC to adopt clearer and tailored interpretations of key concepts underpinning the new ADM transparency obligation, including when a system is “substantially and directly related” to making a decision, and what decisions “significantly affect” an individual’s rights or interests. BSA also recommended that the Guidance distinguish between controllers and processors when interpreting who has “arranged for” the use of ADM.