Submission to CDR Bill – Further Consultation and Designation Instrument for Open Banking

CPRC holds the view that:

• The CDR should be renamed to the Data Portability/Transfer Right to more accurately reflect its functions;
• There is a signficant need for a whole-of-government approach to economy-wide data protection reform to address the risk of CDR data leakage outside the system;
• CDR data should be prevented from transfers to non-accredited third parties in the absence of reform to economy-wide data protection;
• Privacy by Design be embedded in the legislation by ensuring redundant data is deleted by default;
• Consumers should be provided with their CDR information for free without restrictions;
• Consumers should have access to profiling information/categories/scores observed or generated relating to them, and not limited to just accessing information that we observed or provided by the person; and,
• Legislating CDR participants to participate in a centralised dashboard would greatly assist consumers in managing their consent and data portability over time and especially as new sectors are brought into the CDR system.