AGL recently responded to the Treasury’s consultation on the Privacy Impact Assessment (PIA) for the Consumer Data Right (CDR).
A PIA is an assessment of the proposed changes and the impacts it might have on the privacy of individuals. It sets out recommendations for managing, minimising or eliminating the impact which can include alterations to the proposal or stating that the risks are too great for the work to continue. Treasury has completed the PIA draft utilising previously completed work that was both privacy and non-privacy focused for the development of the Consumer Data Right.
Our submission highlights key concerns on the completeness and timing of the PIA and general concerns on the Exposure Draft Treasury released in December 2018.
We recognise the immense amount of work Treasury is currently trying to complete within very tight timeframes, however we maintain that the goal should be a well-considered and fully-planned CDR regime, rather than the pursuit of a specific implementation date.
We encourage the relevant Government bodies and officials to re-consider the proposed timeframes for CDR implementation to ensure there are no unintended consequences for consumers and their privacy.
AGL’s full submission to the PIA can be read here.
AGL’s previous submissions to Treasury can be accessed here.
AGL has also made a submission to the latest round of technical consultation by CSIRO Data61 which can be read here.