ACCAN recently submitted to the Digital Identity Legislation Phase 2 consultation. While ACCAN welcomed several of the provisions included in the draft legislation we had concerns about the following:

• The practical feasibility of consumers opting out of the Digital Identity System,
• The effectiveness of the publicly accessible Participant Register to assist consumer choice,
• The complexity of the tiered system of Accredited Participants,
• The ability for some consumers to understand the complexity of the system and provide genuine consent to collection and use of their data,
• The effectiveness of a Trustmark system without an accompanying consumer education program,
• The lack of enforceability of the proposed liability and redress framework
• The fact that the Oversight Body is not required to monitor resolution outcomes and guarantee consumer compensation or redress, and
• Allowing Relying Parties to charge consumers for use of the Digital Identity System.

Download: Digital Identity Legislation Phase 2 Submission.pdf151.66 KB

Download:  Digital Identity Legislation Phase 2 Submission.pdf831.76 KB