The following headings represent the main arguments and criticisms made in several key submissions to the PJCIS. The ‘statement of compatibility’ contained in the "Revised Explanatory Memorandum" claimed the regime did not breach Australia's human rights obligations under the ICCPR. However several submissions made to the PJCIS questioned the Bill's compatibility with several human rights principles. In its 2014 submission, the Australian Privacy Foundation argued the Bill was incompatible with fundamental human rights and freedoms, especially the right to privacy. It pointed to a considerable body of legal opinion that has concluded that laws mandating blanket retention of metadata breach international human rights law. It submitted that the Bill breached fundamental rights to privacy because it was neither necessary for nor proportionate to legitimate national security and law enforcements objectives. According to the APF, blanket data retention regimes are disproportionate because they ‘indiscriminately mandate the retention of data relating to entire populations, irrespective of the nature of the data or of whether or not there is a reasonable suspicions of a serious threat posed by those to whom the data relates’. The APF referred to several key international law decisions, including reports of the UN High Commissioner for Human Rights and Human Rights Council, which all found metadata retention regimes breached human rights, especially the right to privacy. A similar position was taken by the Law Institute of Victoria (LIV), which submitted that, quoting the UN High Commissioner for Human Rights, ‘even the mere possibility of communications information being captured creates an interference with privacy, with a potential chilling effect on rights, including those to free expression and association’. As a result, the LIV submitted that mandatory third party data retention regimes are neither necessary nor proportionate, irrespective of increased concerns regarding national security threats. Australian Lawyers for Human Rights (ALHR) also submitted concerns that the Bill constituted a serious and unreasonable infringement of the rights of law-abiding Australians. According to the ALHR, the Bill was an ‘indiscriminate, society wide’ invasion of privacy, which rebutted the presumption of innocence. Additionally, the ALHR contended the Bill infringes other human rights not acknowledged in the "Memorandum", in particular, the right to be treated with dignity (Article 1, Universal Declaration of Human Rights), freedom from arbitrary interference with privacy, family, home or correspondence (Article 12, Universal Declaration of Human Rights). The ALHR also submitted the Bill was likely to chill freedom of association (Articles 21 and 22, ICCPR and Article 20, Universal Declaration of Human Rights), the right to free development of one's personality (Article 22, Universal Declaration of Human Rights), the right to take part in the conduct of public affairs (Article 25, ICCPR), and press freedoms.