I'm recommending that all of the executive branch be covered by the Privacy Act, including the PMO and ministers' offices. Why? The Privacy Act is intended to provide access by citizens to information that government holds about them. That relates to service delivery, to conferring rights. There is personal information held in ministers' offices and the PMO that is extremely relevant to service delivery and how rights are delivered.
Many statutes provide statutory responsibilities to ministers, who then delegate them in the bureaucracy. A lot of the information that relates to these questions is in the bureaucracy, and that's currently accessible. But ultimately it's the minister who's responsible to make these determinations, and in some cases the ministers personally do make these decisions. It shouldn't matter whether the information rests in the bureaucracy or in a minister's office if it's the same kind of information that can potentially be used for the same statutory purposes.