Our submissions

Engaged in multiple sectors, our team conducts rigorous consumer and policy research to uncover market failures and consumer harm. We actively collaborate with partners, leveraging national and international perspectives to identify and understand issues within markets. By openly sharing insights, we contribute to the creation of impactful policy solutions, fostering momentum for positive change and advocating for consumer welfare.

June 4, 2019

Submission to Department of Industry, Innovation and Science – Artificial Intelligence: Australia’s Ethics Framework

We strongly support the development of an AI Ethics Framework in Australia in combination with strengthening laws and regulation to protect consumers.

March 22, 2019

Submission to the ACCC Consultation Paper: Data Access Models for Energy Data

As noted in the Consultation Paper, the selection of energy data access model will affect the cost and operation of the Energy CDR system.

February 14, 2019

Submission to the Consultation on the ACCC Digital Platforms Inquiry Preliminary Report December 2018

CPRC noted the lack of an integrated framework for consumer data management and regulation in Australia and recommends a full and thorough economy-wide review of our data governance framework.

October 12, 2018

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.

October 12, 2018

Submission to ACCC CDR Rules Framework

CPRC continues to highlight the benefit and need for the implementation of economy-wide reforms in Australia alongside the introduction of the CDR.

October 2, 2018

Submission to AHRC Human Rights and Technology Consultation

Consumer data is a central research priority for CPRC due to the rapidly growing online marketplace, early adoption of digital technology by Australians, and the emerging benefits and risks to consumers of big data amalgamation.

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September 7, 2018

Submission to Treasury Laws Amendment (CDR) Bill 2018: Exposure Draft

It is CPRC’s view that the CDR is a positive reform in the sense that it may – with appropriate protections – provide consumers with improved access to their data and give them power to direct the transfer of their data to a nominated accredited third-party.

August 8, 2018

Submission to new Australian Government Data Sharing and Release legislation – Issues paper

As a general observation in relation to current policy issues explored in this consultation, CPRC notes the current lack of consideration in the Issues Paper of the appropriate notice and consent standards for data sharing between entities, particularly if the data is identifiable or includes personal information of consumers of government services.

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April 5, 2018

Submission to ACCC Digital Platforms Inquiry Issues Paper

CPRC notes that this Inquiry and cited data practices are not occurring in isolation. One of the most significant challenges of data amalgamation and the impact on competition is that the collection, sharing and use of data is not happening within any one sector, but multiple at the same time. It is therefore important to consider not only the issues associated with genuine consent and control over collection of data but also the sharing and use – by who and for what purpose.

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June 2, 2021

CPRC Submission on CDR Rules – Joint Accounts and Peer-to-Peer in Energy

CPRC’s submission outlines our position opposing the proposed default approach to joint accounts and raising questions about the proposed peer-to-peer structure for energy markets.

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