Submission to Consumer Data Right Energy Rules Framework Consultation Paper

CPRC has previously provided submissions to a number of CDR consultation processes that are relevant to the Consultation Paper, most notably:

• ACCC consultation paper on the Economy Wide Rules Framework
• ACCC consultation paper on Data Access Models for Energy Data
• Australian Treasury issues paper on Future Directions for the Consumer Data Right

Building off this past engagement, this submission outlines issues for the ACCC to consider when developing the energy rules framework (the “Rules”). In particular – this submission focuses on three areas relevant to the Rules:

1. Data sets and consumer experience

2. Building inclusivity into the design of CDR in energy

3. Privacy and consumer protections

Throughout the submission we highlight areas of the CDR in energy Rules that need to be geared toward building consumer trust in data access processes and protections.1 It is important to recognise that as consumer data begins to be amalgamated across the economy (initially in the banking and energy sectors) this will enable very detailed profiling of consumers that can lead to risks of harm, as well as be at odds with consumer expectations of how their data will be used.2 The submission therefore concludes by drawing attention to strategic policy and regulatory actions – applying across the economy – that we consider are fundamental to the sustained success of the CDR reform programme.