Unpredictable Database Compliance Obligations

Section 56 grants the Minister unilateral power to declare "certain classes of information" as critical electronic records without defining criteria for what constitutes "national security" or "economic or social wellbeing" concerns. This designation triggers mandatory registration requirements (51) including disclosure of database locations and administrator details, but businesses have no way to predict which databases will be designated or challenge unreasonable classifications. The lack of statutory criteria, consultation requirements, or appeal mechanisms creates fundamental regulatory uncertainty that undermines business planning and investment decisions for any data-driven enterprise.