Submission: Statutory Review of the Consumer Data Right – Issues Paper

The Consumer Data Right (CDR) reform has not focused on its core intention – delivering benefits to consumers. The scope of CDR applicability continues to grow while processes underpinning data sharing to enable basic transactions and comparisons within the banking sector (currently the most mature CDR regime) are not yet seeing benefits flow through to consumers. .

In its submission on the Statutory Review of the Consumer Data Right, CPRC recommends the Government to use the review to consider the following to ensure a more consumer-centric implementation of CDR:

• Develop clear consumer-centric success metrics.
• Implement consumer protections that evolve beyond notification and consent and into placing obligations on businesses using consumer data. The CDR regime should not over-rely on disclosure or perpetuate consent fatigue among consumers.
• Adequately fund consumer representation to ensure consumer views are represented in the CDR consultative processes.
• Conduct a cost-benefit analysis that identifies direct benefits to consumers across the CDR ecosystem.
• Establish safeguards through economy-wide protections.
• Develop and implement clear enforcement outcomes that hold CDR entities accountable when they fail to operate within CDR rules.
• Consider a sector-neutral, use-case focussed economy-wide roll-out.