The Privacy Commissioner has suggested in a submission to the Office of the Access Card that a number of amendments be made to the Exposure Draft of the Human Services (Enhanced Service Delivery) Bill 2007, including:

• The guiding policy setting for the register should be to collect
  the minimum amount of personal information and this should be reflected
  in the legislation.
• While the Draft states that it is not an object of the Bill
  that access cards be used as a ‘national identity card’, it is
  suggested that community trust be further enhanced by recasting this
  provision and including a statement that the objects of the Bill
  include to prohibit the access card being used as a national identity
  card.
• The legislation should state that the access card number
  (and related identifiers) do not become unique identifiers for each
  individual, which could be used, shared or adopted by Australian
  Government agencies, State and Territory agencies, or the private
  sector.
• The legislation should prescribe, in detail, a statutory
  process for assessing and approving any future uses of the access card
  and associated systems (such as the register).