Date posted: 01/07/2022

Submission to the National Data Security Action Plan

We seek consolidation of the various plans and strategies for managing data across Government that can become the baseline for all levels of government

Our submission to the Department of Home Affairs on its National Data Security Action Plan calls for consolidation of the existing 14 instruments and 9 Government agencies tasked with managing and securing data from generation to storage.

We raise our concern that another plan will not increase awareness but add another layer of complexity for manufacturers of products to manage and store data, users of that data such as our members and the generators of data, the Australian public.

Our submission outlines the obligations of our members to be transparent with clients on why data is being collected and how it will be used and stored. In addition, that our members are also required to take reasonable steps to validate the security credentials of any outsourced provider of data storage.

We also note that the consumer data right is a key pillar in the Governments data strategy and we repeat our concerns raised in other submissions that the rollout to date has disempowered consumers and their trusted adviser and inhibited innovation based on CDR data. 

We seek for the Government to undertake genuine consultation with consumers to understand the level of information they want about storage of their data and in what form they wish that information to be made available.

Joint submission to the statutory review of the consumer data right 

The joint accounting bodies are concerned that the CDR legislative framework undermines consumers’ control of their data and inhibits innovation.  

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