ACCAN has responded to the Digital Transformation Agency’s consultation paper on proposed laws for the Australian Government’s Govpass digital identity platform.

ACCAN’s recommendations included:

  • All privacy and consumer protection safeguards in the Digital Identity Framework must be enshrined in law to ensure compliance;
  • The definition of Digital Identity should be harmonised with the revised Privacy Act to create a robust network of privacy protections for consumers; and
  • A charging framework should not be introduced as it will discourage some non-government organisations from using the Digital Identity system.

In addition, ACCAN recommended that the Digital Identity legislation should:

  • Ensure the system remains voluntary and does not become mandatory;
  • Prevent personal information and profiling of individuals from being commercialised;
  • Guarantee ‘function creep’ does not erode privacy over time;
  • Prohibit the collection and processing of personal information about children under the age of 16 without express authorisation by a responsible adult;
  • Secure accessibility to the Digital Identity system for all consumers without discrimination;
  • Enshrine all privacy and consumer protection safeguards in the Trusted Digital Identity Framework (TDIF); and
  • Grant power to a permanent Oversight Authority to ensure privacy and consumer safeguards are strictly enforced.


ACCAN also made recommendations on the role of the Oversight Authority, including investigation of complaints and running a complaints handling mechanism.

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