Question
Is the data set an ADR/OSP derives from consumer data received from an accredited data holders viewed as CDR data?
Answer
Yes.
Section 56AI of the Competition and Consumer Act 2010 gives the definition of CDR data.
The Explanatory Memorandum to the legislation that introduced s.56AI confirms that data derived from CDR data is still CDR data. It states, at para 1.114:
The definition of CDR data includes data that is ‘derived’ from data listed in the designation instrument. It means that the Privacy Safeguards continue to apply to CDR data that relates to a consumer even if it has been subsequently transformed in the hands of the accredited data recipient.
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