This response outlines our key concerns regarding consequences of the proposed Rules changes and offers specific suggestions where different approaches may produce better results for consumers. We emphasise that the success of CDR must be measured in terms of consumer outcomes – the extent to which consumers receive: higher quality, or more competitively priced products and services; the value from their data and personal information; and more genuine control over their CDR data. Short-sighted approaches to assessing the success of the scheme by measuring the number of accredited recipients participating fails to put consumers first. A weaker CDR protection regime could enable a large amount of participants, but can also threaten information security, erode consumer trust and allow the value of consumer data to be extracted by industry at ever greater rates, rather than accruing with consumers themselves.

Submission to the ACCC CDR Rules Expansion Amendments Consultation Paper