Submission to The Treasury’s Consumer Data Right Amendments (version 3)

CPRC urges Treasury to heed the concerns of consumer organisations and take appropriate steps to mitigate risks to consumers through the development of these rules to achieve what was originally intended for Consumer Data Right (CDR) – giving consumers greater control over their data. We’ve noted that some of the recent proposed amendments seem counterintuitive to the core intention of the regime. We have also provided feedback on specific amendments relating to joint account holders, trusted advisers and CDR insights based on our research. Future directions for the CDR must continue to be envisaged, for the consumer, about the consumer, and placing the control of data in the hands of the consumer.

Our recommendations:

• Conduct a cost-benefit analysis detailing the benefits to consumers of implementing these amendments
• Implement Privacy Act reforms to ensure the environment surrounding the CDR provides sufficient protection for consumers as their data is opened up
• Outline the process of auditing and enforcing the CDR regime
• Undertake comprehensive consumer experience (CX) testing.