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High Severity

Minister-Appointed Privacy Appeals Tribunal

The tribunal that reviews privacy and data rights disputes is appointed entirely by the Minister and funded by the Authority it oversees, creating structural bias against privacy protection. When individuals or organizations challenge Authority decisions on data classification, sharing mandates, or subject rights, they face a tribunal with no independence safeguardsโ€”no secure tenure, no independent selection process, and financial dependency on the entity being reviewed. This undermines the bill's claimed harmony with data protection laws by ensuring the appellate body has institutional incentives to defer to the data-sharing Authority rather than robustly protect privacy rights.