Scarlet Alliance and The National Association of People with HIV Australia (NAPWHA) joint submission on the Data Availability and Transparency Bill 2020 Exposure Draft Consultation Paper on November 6, 2020.
“It is of concern that the simplified outline of the Bill in s.4 attributes to the National Data Commissioner, as the regulator for the data sharing scheme, the function of advocating only for the greater sharing and release of public sector data. This ignores the reality that, in many circumstances, data is sensitive and sharing and release should be advocated against; such as where the risk of harm outweighs benefit to the person whose data is being shared. Ever greater sharing of information is not self evidently beneficial and the section should not assume as much.
The Commissioner’s role should be, first and foremost, to protect the privacy and safety of individuals against threats of unnecessary or unauthorised sharing of their data. Only where privacy has been safeguarded and where perilous sharing of data has been prevented, should the Commissioner be tasked with promoting broader sharing of information.”
