I would say that the bill specifically gives the Privacy Commissioner the ability to issue administrative monetary penalties, which is a very welcome addition.
The one thing that strikes me, which I would like to highlight, is the fact that at the moment the OPC cannot issue an AMP for breaches of proposed section 12. I think this is quite an important section, since the purposes of data processing are the pillar for determining what is or is not a legitimate use of data. Therefore, I would recommend including proposed section 12 as a kind of enforceable ground for the OPC.