The exposure draft of the Code is an extremely welcome development, and Digital Rights Watch is broadly supportive of this initiative. The development of the Code represents an important step forward for Australia’s privacy landscape, which otherwise lags behind many comparable jurisdictions. With many Australians expressing concerns about the dangers and problems of online environments, especially for young people, the draft Code represents a rights-respecting approach to addressing a range of these concerns.
- In particular, Digital Rights Watch supports:
- A requirement that the collection, use and disclosure of personal information be in the best interests of the child
- Vastly improved concepts of consent, which move away from mere tick-a-box compliance
- Expanded coverage of personal information covered by the Code, including information like geolocation
- The right to delete, which is important for autonomy, cybersecurity and freedom from invasive corporate surveillance
Many components of the Code are rights that adults would expect to have already, but do not. Digital Rights Watch strongly supports further privacy reform to achieve this, and notes the government has committed to many of these changes as part of the second tranche of privacy reform.
Digital Rights Watch does have some concerns about gaps in implementation and potential side-effects of some of the COPC, which is addressed in our submission.