Financial Rights’ submission predominantly addresses Proposal 2: Interaction of the Privacy Safeguards with the Privacy Act. We have significant concerns with the complexity and weakness of the proposed new privacy framework, especially:
• the overarching confusing, convoluted and piecemeal nature of the CDR;
• the treatment of many data recipients as data holders; and
• the exemption of data holders from the Consumer Data Right (CDR) Privacy Safeguards.
