of services, such as the multi-disciplinary Children’s Teams and introduced new institutional capabilities, such as information sharing requirements. The Vulnerable Children’s Plan, vested under the sections 6 and 7 of the Vulnerable Children’s Act, is yet to be introduced (see paragraph 25 above). 5. Civil rights and freedoms A. Fundamental freedoms – Privacy/Expression/Association/Religion Relevant provision of the CRC: Articles 13, 14, 15 and16. Information sharing 60. Since 2011, the introduction of enhanced information sharing capabilities amongst government agencies has given rise to issues pertaining to the rights of children to privacy under Article 16. 61. Amendments made to the Privacy Act 1993 in 2012 have introduced Approved Information Sharing Agreements (AISAs), a regulatory instrument that enables government agencies to share personal information in circumstances that would otherwise breach the Information Privacy Principles contained in the Privacy Act. AISAs are developed via a robust statutory process that is overseen by the Privacy Commissioner. 62. A Vulnerable Children’s AISA was developed and passed into regulation in 2015. The AISA enables personal information on vulnerable children to be collected, stored and shared between specified Government agencies through a Vulnerable Children’s database and triage hub. The information is then used to inform the delivery of services and interventions, including those of multi-disciplinary Children’s Teams and improve inter-agency co-ordination. 63. The review of CYF also contemplates the introduction of predictive risk modelling to identify children who may be at heightened risk of harm.27 Predictive risk modelling assigns risk through an assessment of information regarding the child’s family background and circumstances, such as the existence of previous child protection interventions, drug or substance abuse and benefit history. It therefore requires personal information about the child and their family history from relevant agencies to be collected. The Commission has raised concerns with the Government’s Advisory Expert Group on Information Security on the potentially discriminatory impact of predictive risk modelling, particularly if it used to target children of beneficiaries. 27 Terms of Reference for the Modernising Child, Youth and Family Expert Panel, page 2 and 4 15