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Draft Consumer Data Right Privacy Safeguard Guidelines Consultation

27 November 2019

The ABA recommends that the PS GL undergo a second consultation twelve months after the launch of the CDR regime. The ABA recommends that the OAIC institutes a process for annual review (or as CDR documentation is revised) of the PS GL in order to ensure that all cross-references remain up-to-date, complete, relevant and therefore effective. It would benefit readers of the PS GL if the OAIC provided multiple examples where a Privacy Safeguard requires DHs and ADRs to consider what is ‘reasonably needed’ or ‘proportionate’.

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