Ai Group welcomed the opportunity to make a submission on the Exposure Draft of the Privacy Legislation Amendment (Enhancing Online Privacy and Other Measures) Bill 2021 (OP Bill) by the Attorney-General’s Department (AGD).

Overall, industry recognises the importance of protecting the privacy, safety and security of the Australian community, both in the physical and online realm. Indeed, Ai Group works closely with governments and their agencies in a diverse range of areas. In this mix, the Office of the Australian Information Commissioner (OAIC or Commissioner) has an important specific role to promote privacy protections.

Our submission therefore does not object to the underlying intention behind the Bill, which is to provide appropriate online privacy protections for the Australian community. However, we consider that as a matter of good policy and regulatory practice, proper analysis and assessment of issues, underlying causes, options to address these issues, as well as a robust and considered cost-benefit assessment for any proposed regulatory or legislative change, need to be given to this consultation.

Further, given the potential uncertainties and significant impact on many stakeholders arising from the AGD’s concurrent privacy reforms (i.e. broader review of the Privacy Act 1988 (Cth) (Privacy Act Review) and the OP Bill), the AGD should build more time and stages to enable for proper consultation on these reforms with affected stakeholders.