This submission is made on behalf of the Financial Rights Legal Centre and the Consumer Action Law Centre. We have expressed concern with potential ability for Consumer Data Right data to be disclosed to, and obtained by, non-accredited third parties in multiple submissions over the development of the Consumer Data Right. We remain of the view that non-accredited third parties should be permitted to receive CDR data, and that it is inappropriate for any unaccredited third party to receive and hold CDR data.