Submission to the Department of Prime Minister and Cabinet

ATSE Submission on Australia’s Data Strategy


ATSE welcomes the opportunity to respond to the Department of the Prime Minister and Cabinet’s consultation on Australia’s Data Strategy.

Data sharing remains a challenge in many organisations, with a strong focus on data privacy. In practice, the real concerns relate to not only privacy but also sensitivities of the data, data quality, and the impact of decisions made from insights generated from the data. Given these concerns, it is ATSE’s view that the Australian Data Strategy should include:

  1. A nationally consistent approach to metadata requirements.
  2. A nationally consistent assessment of data quality measures.
  3. Develop and adopt consistent patterns of data sharing.
  4. Nationally consistent and unambiguous definitions of Personal Data, Personal Information, and Personally Identifiable Information
  5. Nationally consistent standard on terminology, use cases, ways of sharing, roles and responsibilities, governance, and security.
  6. Moving away from the Five Safes framework in favour of more sophisticated data sharing/data use risk frameworks.
  7. Encouragement for organisations to follow best practice in securing customers’ personal data, and penalties for preventable breaches.
  8. Include within the strategy an approach that establishes Indigenous Data Sovereignty over data about Indigenous peoples that may impact on the lives of Indigenous peoples and communities.