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DSPANZ provided a submission to the Department of Finance's consultation on the draft Digital ID Rules, Digital ID Accreditation Rules and Accreditation Data Standards on 25 June 2024. 

At a high level our submission provided overarching feedback on private sector participation in the Australian Government Digital ID System (AGDIS) and specific commentary on select rules, including:

  • DSPANZ is concerned that the two year delay for private sector participation in the AGDIS will create a compliance deadline for DSPs, with customers expecting this functionality in software. 
  • Without a clear indication of the charging framework and the Australian Taxation Office's (ATO) stance on interoperability, it will be challenging for DSPs to appropriately budget and plan for utilising digital ID in two years. 
  • As the Department of Finance (the Department) considers how individuals acting on behalf of businesses will work within the digital ID system, we expect that ATO's Relationship Authorisation Manager (RAM) will become accredited within the AGDIS.
  • The Department should look to reduce the compliance burden in meeting the digital ID rules by leveraging and recognising existing security frameworks and reporting obligations. 
  • The Digital ID Rules and Accreditation Rules should state minimum and maximum record retention periods. 
  • The Department should align review periods and enduring consent timeframes with the Consumer Data Right requirements. 

Access the full copy of this submission here

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