The Department of the Treasury, as one of the agencies involved in the implementation of the Consumer Data Right (CDR) regime, recently appointed Maddocks lawyers to conduct an independent privacy impact assessment regarding the initial implementation of the CDR. Maddocks has completed their draft privacy impact assessment report and requested stakeholder feedback on this draft.

Given that the CDR regime will be extended to the telecommunications sector, after first being implemented in the banking and energy sectors, ACCAN has been engaging with issues relating to the CDR and its implementation. This includes a short response to Maddocks’ draft privacy impact assessment.

ACCAN provided feedback on the 10 recommendations Maddocks made in the privacy impact assessment. We agreed, for instance, that the privacy impact assessment should be continually updated as the CDR regime is applied to different sectors, and agreed that further guidance should be provided around the operation of the CDR regime, to ensure that all actors involved, including CDR consumers, clearly understand their rights and obligations.

In our response ACCAN also reiterated some of our concerns regarding the CDR regime. One of our key concerns is the scope of consumer privacy protections within the CDR regime. ACCAN believes that the privacy protections and obligations established by the CDR regime should be extended to ensure that the CDR Data of consumers is appropriately protected as it moves within and outside of the CDR regime.

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