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The Office of the Australian Information Commissioner (OAIC) recently sought feedback on its Draft Privacy Safeguard Guidelines for the Consumer Data Right (CDR) regime. The Guidelines explain the Information Commissioner’s interpretation of the privacy safeguards and Consumer Data Rules, and provide examples of how the privacy safeguards and Consumer Data Rules may apply in certain situations. As the CDR regime will be extended to the telecommunications sector in the future, after first being implemented in the banking and energy sectors, ACCAN provided a response to the OAIC’s Guidelines.

ACCAN provided general feedback about how the Guidelines could be strengthened to ensure greater protection for CDR consumers. We suggested that additional examples and scenarios be included in the Guidelines, and that these should continue to be added as the CDR regime is implemented and real consumer experiences come to light. We asked for greater clarity around the use of certain phrases, such as ‘reasonable steps’ and ‘possible adverse consequences for a consumer’, and called for stronger requirements relating to the CDR policies of CDR entities.

Our response also discussed the need for clear, consistent, accessible and easy-to-understand communication with consumers. This must include firm timeframes so that CDR consumers are aware of when they can expect certain types of communication from different CDR entities. Finally, ACCAN outlined that measures must be taken to ensure that the accessibility needs of CDR consumers are appropriately met throughout all aspects of the CDR regime.

Download: docxOAIC Draft Privacy Safeguard Guidelines - ACCAN submission88.54 KB
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