I couldn't hazard a guess at that one LB. As far as I am concerned, if you provide a photograph for an ASIC then there are very specific cyber security requirements for safeguarding that data, including photographs. If CASA are taking the photo and using it for something else that may well be contrary to the requirements of the Auscheck legislation. Does the CASA application say anything about using the photo for other purposes? Ask CASA, if not happy with the response, contact the Department of Home Affairs.
From the website:
For information on these processes email the department at [email protected] or call on 1300 791 581 (option 2).
I guess that as CASA are ceasing as an IB, they will ask you to provide a photo by some other means for their Avmed requirements.