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We wish to submit the following recommendations for amendment of the Data Protection Bill. While overall we are highly supportive and enthusiastic as to the positive impact of the Bill, there are several provisions that if left as is could negatively impact innovation in the technology and finance sectors, and hinder both competition and consumer rights.
Generally, it is a good bill that is well improved compared to previous versions. For example, the object of the proposed law is positive as opposed to previous versions that included exemptions in the objects. There are also fewer limitations on the right to privacy.
There could be further sharpness on engagement of data subjects with data controllers and processors. There are several clauses that propose response to the the data subject “within a reasonable period”. While the rationale behind this is to ensure that data processors can continue with their core business even where there are numerous requests, there should be a better balance between business interests and data subject right to information.