Mr. Dale Sunderland:

I too will come in on the point regarding head 121 and whether it conflicts with GDPR. I do not think it conflicts with GDPR, per se. It is about the balancing of rights and what is trying to be achieved. One must determine whether the purpose that is trying to be achieved justifiably outweighs the other rights of individuals. Transparency is a key objective. If that case is well made and it is determined that there is a justification, due cause or proportionate and necessary reason for publishing those details, that can meet the standard under the data protection requirements. In doing so, one identifies the risks and the mitigations of those risks. If the data were to be published, they would be published with safeguards such as, for example, that they would be non-searchable and there would be measures to prevent screen scraping. It is about assessing the risks and putting the safeguards in place and then that balance between transparency and personal privacy. I cannot give the Senator a definitive answer because it is about weighing up the intrusion into the individual's personal data and his or her right to privacy compared with other rights and freedoms and legitimate public policy objectives. That is the determination that would have to be made.

Obviously, the platforms would have obligations to ensure the data are secured and a whole suite of obligations in terms of complying with the GDPR if they are required to publish this information under legislation.