This submission addresses two of the four policy reform areas in the Productivity Commission’s inquiry into
Pillar 3: harnessing data and digital technology:

• support safe data access and handling through an outcomes-based approach to privacy
• enable artificial intelligence's (AI’s) productivity potential.

In these areas, the submission states that the interim report’s proposals:

• are based on an incomplete understanding of, or engagement with, the domestic and international legal environment, the existing evidence of AI harms and risks, and regulatory gaps already identified through extensive stakeholder engagement
• fail to engage with significant empirical research that highlights the risks of AI and data-driven technology (and the uneven distribution of those risks), and raises doubts about much-hyped productivity gains
• err in the description of international development
• disregard a large number of recent, evidence-based findings by Commonwealth regulators, government departments and law reform bodies following extended consultation and evidence gathering processes.