Right to privacy vs age verification: how the balance is kept
Introduction
The minimum age of 18 for online gambling in Australia requires mandatory verification of the identity and date of birth of users. At the same time, the law guarantees everyone the right to confidentiality and protection of personal data. In the confluence of these two requirements, operators are looking for technical and organizational solutions that ensure the reliability of verification without excessive collection or leakage of sensitive information.
1. Legal basis
1. Interactive Gambling Act 2001 (IGA)
Strict ban on accepting bets from persons under 18 years of age.
The duty of operators to "verify the identity and age" of the client before the interaction begins.
2. Privacy Act 1988 и Australian Privacy Principles (APPs)
Seven basic principles of personal data processing: collection of only "necessary" volume, transparency, security, access and deletion rights.
Online casino operators are required to comply with APP 3 (collection of personal data) and APP 11 (secure storage and deletion).
3. State-level Data Protection Acts
For example, Victoria has the Information Privacy Act 2000, which strengthens measures to protect users' digital footprints.
2. Technical approaches to verification without excessive collection
1. eID providers and data tokenization
Instead of directly transferring copies of the passport to the operator, the user is checked in Equifax, DocuSign ID or AusID.
The operator receives a "verified boolean flag" (age\_ verified: true) and a minimum set of attributes (for example, year of birth), without passport details.
2. Zero-knowledge proof (ZKP)
Cryptographic method: the user proves that he is ≥18 years old without revealing the exact date of birth.
In the pilot project, ACMA, together with blockchain startups, demonstrated the operability of ZKP for age verification.
3. Data partitioning
Sensitive documents are stored in an isolated verification database to which the access application platform does not have.
When you change the status (change the last name or return the passport), the data is automatically deleted by the trigger.
3. Organizational and procedural measures
1. Minimizing the amount of data collected
Collection of only necessary: name, year of birth, unique identifier of the check.
Prohibition on storing copies of documents: only the hash value for audit and verification proof is stored.
2. Clear privacy policy and consent
Prior to registration, the user receives a short notification about what data will be collected and why.
Mandatory consent (opt-in) for data storage explaining the right to delete or receive a copy (APP 12-13).
3. Retention periods and data deletion
According to ACMA recommendations: delete all redundant data no later than 6 months after the last activity.
Automated process "data purge" with a report on execution for the regulator.
4. Ethical and business considerations
1. Trust and reputation
Publishing transparent Privacy Act compliance reports builds customer trust.
Obtaining "Privacy Accreditation" from the Office of the Australian Information Commissioner (OAIC) increases competitiveness.
2. User experience
The easier it is to verify without multi-stage submission, the higher the conversion of registrants.
Balancing verification reliability with minimal entry barriers is a key factor in user retention.
3. Antifraud and AML requirements
In addition to age verification, operators are required to conduct money laundering (AML) checks.
The consolidation of KYC (Know Your Customer) and age-verification processes allows you to reduce duplication and assemble one "compliance package" without redundancy.
5. Practical recommendations for operators
1. Integration of certified eID services
Choose a provider with local data centers in Australia and the appropriate certificates (ISO 27001, SOC 2).
Configure tokenized attribute passing to minimize PII (Personally Identifiable Information).
2. Regular audit and testing
Annual compliance check of Privacy Act and APP: processes, policies, technical channels.
Conducting "red team" attacks on the verification system to identify vulnerabilities.
3. Transparent communication with users
After passing age-gate, show messages about what data will be deleted automatically and how it can be managed.
Available section "My data" in your personal account with the ability to download verification attributes and request deletion.
Conclusion
The balance between the right to privacy and the need to make sure the user reaches the age of 18 is a key challenge for the online gambling industry. The legal framework (IGA and Privacy Act) combines strict verification requirements and strict principles of personal data protection. Modern technologies (eID, ZKP, tokenization), coupled with well-thought-out data processing procedures, allow operators to achieve compliance with both requirements - to protect minors and respect the right of adults to privacy.
The minimum age of 18 for online gambling in Australia requires mandatory verification of the identity and date of birth of users. At the same time, the law guarantees everyone the right to confidentiality and protection of personal data. In the confluence of these two requirements, operators are looking for technical and organizational solutions that ensure the reliability of verification without excessive collection or leakage of sensitive information.
1. Legal basis
1. Interactive Gambling Act 2001 (IGA)
Strict ban on accepting bets from persons under 18 years of age.
The duty of operators to "verify the identity and age" of the client before the interaction begins.
2. Privacy Act 1988 и Australian Privacy Principles (APPs)
Seven basic principles of personal data processing: collection of only "necessary" volume, transparency, security, access and deletion rights.
Online casino operators are required to comply with APP 3 (collection of personal data) and APP 11 (secure storage and deletion).
3. State-level Data Protection Acts
For example, Victoria has the Information Privacy Act 2000, which strengthens measures to protect users' digital footprints.
2. Technical approaches to verification without excessive collection
1. eID providers and data tokenization
Instead of directly transferring copies of the passport to the operator, the user is checked in Equifax, DocuSign ID or AusID.
The operator receives a "verified boolean flag" (age\_ verified: true) and a minimum set of attributes (for example, year of birth), without passport details.
2. Zero-knowledge proof (ZKP)
Cryptographic method: the user proves that he is ≥18 years old without revealing the exact date of birth.
In the pilot project, ACMA, together with blockchain startups, demonstrated the operability of ZKP for age verification.
3. Data partitioning
Sensitive documents are stored in an isolated verification database to which the access application platform does not have.
When you change the status (change the last name or return the passport), the data is automatically deleted by the trigger.
3. Organizational and procedural measures
1. Minimizing the amount of data collected
Collection of only necessary: name, year of birth, unique identifier of the check.
Prohibition on storing copies of documents: only the hash value for audit and verification proof is stored.
2. Clear privacy policy and consent
Prior to registration, the user receives a short notification about what data will be collected and why.
Mandatory consent (opt-in) for data storage explaining the right to delete or receive a copy (APP 12-13).
3. Retention periods and data deletion
According to ACMA recommendations: delete all redundant data no later than 6 months after the last activity.
Automated process "data purge" with a report on execution for the regulator.
4. Ethical and business considerations
1. Trust and reputation
Publishing transparent Privacy Act compliance reports builds customer trust.
Obtaining "Privacy Accreditation" from the Office of the Australian Information Commissioner (OAIC) increases competitiveness.
2. User experience
The easier it is to verify without multi-stage submission, the higher the conversion of registrants.
Balancing verification reliability with minimal entry barriers is a key factor in user retention.
3. Antifraud and AML requirements
In addition to age verification, operators are required to conduct money laundering (AML) checks.
The consolidation of KYC (Know Your Customer) and age-verification processes allows you to reduce duplication and assemble one "compliance package" without redundancy.
5. Practical recommendations for operators
1. Integration of certified eID services
Choose a provider with local data centers in Australia and the appropriate certificates (ISO 27001, SOC 2).
Configure tokenized attribute passing to minimize PII (Personally Identifiable Information).
2. Regular audit and testing
Annual compliance check of Privacy Act and APP: processes, policies, technical channels.
Conducting "red team" attacks on the verification system to identify vulnerabilities.
3. Transparent communication with users
After passing age-gate, show messages about what data will be deleted automatically and how it can be managed.
Available section "My data" in your personal account with the ability to download verification attributes and request deletion.
Conclusion
The balance between the right to privacy and the need to make sure the user reaches the age of 18 is a key challenge for the online gambling industry. The legal framework (IGA and Privacy Act) combines strict verification requirements and strict principles of personal data protection. Modern technologies (eID, ZKP, tokenization), coupled with well-thought-out data processing procedures, allow operators to achieve compliance with both requirements - to protect minors and respect the right of adults to privacy.
