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ABSIA submitted to the Office of the National Data Commissioner's Data Sharing and Release - Legislative Reforms Discussion Paper on 15 October 2019. 

Prior to preparing our submission, representatives from the Office of the National Data Commissioner (ONDC) joined members of the ABSIA Board for a conference call to discuss themes of the discussion paper. 

In summary, our response put forward the following:

  • The unintended consequences of re-identifying individuals within data sets is a significant challenge for the framework;
  • If there are costs to accessing data, it may prevent smaller businesses from being able to participate in the framework and benefit from shared data;
  • The name of the legislation should be changed to reflect the shift towards data sharing rather than release;
  • The purposes for data sharing meet our expectations. Within the purposes, there are many opportunities to enhance the end user's experience with government services, while also allowing the government to better analyse their own processes;
  • The software development industry would benefit greatly from accessing shared data in being able to find market gaps and new opportunities to create innovative products and solutions for businesses;
  • A more detailed Risk Management Framework covering each of the five Data Sharing Principles is required to ensure the communities feel more confident;
  • We recommended a penalty approach based on controlled data sharing rather than open data release;
  • Encouraged the ONDC to develop relationships with the ATO, industry associations, organisations and businesses to support the legislation; and
  • Noted the potential confusion between 'data service provider' and 'Digital Service Provider' should the former be shortened to 'DSP' given the use of DSP by the ATO and software industry. 

Access a copy of the full submission here