Anonymous Options Check · APP 2 anonymity and pseudonymity

Do I Have to Let People Deal With Me Anonymously?

Q: What does APP 2 of the Privacy Act require?

APP 2 (Anonymity and pseudonymity) requires that individuals be given the option of not identifying themselves, or of using a pseudonym, when dealing with your business in relation to a particular matter — unless it's impracticable to deal with them anonymously, or you're required or authorised by law to deal with identified individuals.

Q: When can a business require identification under APP 2?

Two exceptions apply: it is impracticable to deal with the individual anonymously or under a pseudonym (for example, delivering a physical good to an address), or the business is required or authorised by an Australian law, or a court/tribunal order, to deal with identified individuals (for example, AML/CTF customer identification, health records law, or a tax invoice above the GST threshold).

Q: What does the free anonymous options check check?

It checks the customer touchpoints you select against a catalogue of 19 common Australian business touchpoints, flagging which ones are typically required to offer an anonymous or pseudonymous option under APP 2, and which are exempt because identification is impracticable or required by law.

Select the touchpoints where your business deals with individuals. Get an instant APP 2 check across 19 common Australian business touchpoints.

Under APP 2 of the Privacy Act 1988 (Cth), individuals must have the option of not identifying themselves, or of using a pseudonym, when dealing with your business — unless it's impracticable, or you're required or authorised by law to deal with identified individuals. Select the touchpoints below to see which ones need an anonymous or pseudonymous option.

Last updated: 2 July 2026

How each touchpoint is scored

Result	Meaning
Compliant	Either you already offer an anonymous/pseudonymous option, or identification is impracticable or required by law at this touchpoint
Gap	Anonymity or pseudonymity is practicable here and no legal exception applies, but you currently require full identification

Why most businesses have at least one gap

Most intake forms default to requiring a full name and verified contact details, whether or not the interaction actually needs it. A general enquiry, a price quote, or a piece of feedback rarely needs a verified legal identity — but the form asks for one anyway because it was built once and never revisited against APP 2.

The exceptions are genuine and common: delivering a physical good needs a real address, a credit or AML/CTF-regulated transaction needs identification by law, and a health service needs an identified patient. The point of this check isn't to remove identification everywhere — it's to separate the touchpoints where it's actually required from the ones where it's just a default nobody questioned.

Free diagnostic tool

Anonymous options check

Select every touchpoint where your business deals with individuals. For each one that's practicable to offer anonymously, tell us whether you currently do. You'll get an instant APP 2 report at a permanent URL you can revisit or share.

Business name (optional)

Which touchpoints apply to your business?

Select all that apply. Where an anonymous option is practicable, tell us whether you currently offer one.

Enquiries & marketing

Sales & service delivery

Regulated transactions

Financial product or credit application Usually exempt Identification is a statutory requirement — APP 2 does not apply here.

Real estate sale, purchase or lease transaction Usually exempt A binding property transaction requires identified parties on both sides.

Health service delivery (clinical appointment, prescription) Usually exempt Safe clinical care and PBS-subsidised prescriptions depend on accurate patient identification.

Sale of an age-restricted product (alcohol, tobacco, gambling) Usually exempt Age verification is a legal precondition of the sale.

Job application or recruitment process Usually exempt Early-stage enquiries can be pseudonymous, but formal applications generally cannot.

Sale requiring a tax invoice over $82.50 (GST-inclusive) Usually exempt The tax invoice threshold creates a statutory identification requirement.

Dealing subject to a court or tribunal order Usually exempt The order itself removes the option of anonymity for this dealing.

When you need an anonymity check

— You've never reviewed your intake forms and touchpoints against APP 2
— You're newly covered by the Privacy Act following the 1 July 2026 threshold removal
— You're drafting or updating your privacy policy and need to document your anonymity exceptions
— You're preparing for an OAIC inquiry or a compliance audit
— You want to know which forms can be simplified without creating a compliance risk

Frequently asked questions

What does APP 2 of the Privacy Act require?

APP 2 requires that individuals be given the option of not identifying themselves, or of using a pseudonym, when dealing with your business — unless it's impracticable, or you're required or authorised by law to deal with identified individuals.

When can a business require identification under APP 2?

Two exceptions apply: impracticability (for example, delivering a physical good to an address) or a legal requirement to deal with identified individuals (for example, AML/CTF customer identification, health records law, or a tax invoice above the GST threshold).

Does a contact form need to ask for a full name?

Generally no. Answering a general enquiry, providing a quote, or handling a complaint doesn't usually require a verified full legal name — a pseudonym or first name is typically sufficient unless a specific legal requirement applies.

What does the free anonymous options check check?

It checks the touchpoints you select against a catalogue of 19 common Australian business touchpoints, flagging which are typically required to offer an anonymous or pseudonymous option under APP 2, and which are exempt.

Select your touchpoints above to get an instant APP 2 anonymity report.

Get my anonymity report →