What's the impact of not having data-sharing agreements in place? It doesn't govern how the data will be used. Essentially, it obviates the consent that users would be able to give as to how their data would be used, which is a very important provision within the Privacy Act itself.
We have problems here with whether the data was being kept accurately in a manner that was complete but also up to date. When I requested my own data, saw my data, and saw how the algorithms were interpreting my passport, reading my name, spelling my name and scrambling my phone number incorrectly, it was very clear to me that this app was shoddily constructed.
Not only do we have a problem with the accuracy of the data but also in terms of how the data is being shared by these entities whose names are all we know about them. That is a big problem when it comes to informed consent as required in the Privacy Act.