The Public Interest Advocacy Centre (PIAC) has provided a submission to the Department of Prime Minister and Cabinet in response to its call for comments on the draft Unified Privacy Principles (UPPs). PIAC, in its submission, provides a brief response on each of the draft UPPs as well as some general comments focussing on the need to ensure that the adoption of UPPs result in great clarity of rights and obligations in respect of the human right to privacy. PIAC seeks a commitment from the Federal Government to not permit any reduction in the rights and obligations in the UPPs through regulations or rules and urges the Government to ensure that all of the obligations are applied to both organisations (non-government entities) and agencies (government entities). PIAC notes the need for more consideration to the drafting and operation of some of the UPPs, including the use and disclosure of personal information for human and social policy research, the approach to direct marketing to non-customers and individuals under 15 years of age as well as the use of sensitive information in direct marketing. PIAC also sought a significant change in approach to UPP 11 dealing with cross-border data flows to ensure that privacy obligations remain on agencies and organisations in Australia where they send data containing personal information off-shore.