ACCC & DSB | CDR Implementation Call Agenda & Meeting Notes | 7th of March 2024
When: Weekly every Thursday at 3pm-4:30pm AEDT
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We acknowledge the Traditional Custodians of the various lands on which we work today and the Aboriginal and Torres Strait Islander people participating in this call.
We pay our respects to Elders past, present and emerging, and recognise and celebrate the diversity of Aboriginal peoples and their ongoing cultures and connections to the lands and waters of Australia.
The Consumer Data Right Implementation Calls are recorded for note taking purposes. All recordings are kept securely, as are the transcripts which may be made from them. No identifying material shall be provided without the participant's consent. Participants may [email protected] should they have any further questions or wish to have any material redacted from the record.
By participating in the Consumer Data Right Implementation Call you agree to the Community Guidelines. These guidelines intend to provide a safe and constructive space for members to discuss implementation topics with other participants and members of the ACCC and Data Standards Body.
⭐ indicates change from last week.
| Type | Topic | Update |
|---|---|---|
| Standards | Version 1.29.1 | Published: 28th of February 2024 Change log |
| Maintenance | Maintenance Iteration 18 commenced on the 7th February 2024 Working Group met on the 6th of March 2024 |
MI 18Agendas Please reach out to [email protected] for an invitation |
| DSB Newsletter | To subscribe to DSB Newsletter | Link here |
| DSB Newsletter ⭐ | 1st of March 2024 | View in browser here |
| Consultation | Decision Proposal 229 - CDR Participant Representation | Placeholder: no close date Link to consultation |
| Consultation | Noting Paper 279 - Accessibility Improvement Plan | No Close Date Link to consultation |
| Consultation | Noting Paper 323 - NFR Workshops | Link to consultation |
| Consultation | Noting Paper 330 - UNSW Reports | Link to consultation |
| Consultation | Decision Proposal 340 - Maintenance Iteration 18 | Link to consultation |
| Consultation | Noting Paper 342 - Information Security Working Group | Link to consultation |
| Survey | If you are a CDR stakeholder, we want to hear about your experience finding and using CDR guidance. The ACCC has released a survey for businesses and individuals who are holder or receivers of CDR data, or who provide services to these parties. This includes, for example, data holders, accredited persons, CDR representatives and third-party service providers. Your response will help us assess the effectiveness of CDR guidance and identify potential areas for improvement. | The survey is available on the ACCC website and will remain open until 25 March 2024. |
| Workshop ⭐ | Title: Identifying risks with LCCD inclusion Date: 19th of March 2024 Time: 2:00PM AEST to 4:00PM AEST |
Register for the workshops |
| CX Guidelines ⭐ | Minor revisions to requirements referenced in wireframes, open source design assets and CX Checklist to reflect July 2023 rules amendments and Decision 333 | CX Guidelines |
Provides a weekly update on the activities of each CDR stream and their work.
| Organisation | Stream | Member |
|---|---|---|
| ACCC | Register and Accreditation Application Platform, Conformance Test Suite & Participant Tooling | Christian |
| DSB | Consumer Experience | Michael |
| DSB | Energy | Hemang |
None this week.
Questions will be received by the community via Microsoft Teams chat before the questions are opened to the floor. Participants can submit questions outside of the CDR Implementation Call to the CDR Support Portal.
In regards to topics for questions, we ask the participants on the call to consider the Community Guidelines when posing questions to the subject matter experts.
| Ticket # | Question | Answer |
|---|---|---|
| 2284 | We're looking into building an account verification service utilising the CDR insight consent model, for the purposes of our customers to confirm a consumer's identity (and bank account details) to prevent fraud. Before we commence this, we wanted to confirm our understanding that the following information is permitted under the insights model: - BSB - Account Number From our reading of the Rules, insights are not permitted to reveal sensitive information (defined within the Privacy Act), and a BSB and account number wouldn't fall under this definition. Please let us know if we are missing anything. |
Thanks for your query on using the CDR insights model for account verification, specifically concerning BSB and account numbers. Under the CDR rules, insights derived from consumer data can be used for specific purposes, including verifying a consumer's identity, account balance, and transaction details (CDR Rules, subparagraphs 1.10A(3)(a)(i)-(iii)). The relevant Explanatory Statement explains that ‘verify’ in the context of CDR insights refers to confirming, denying or providing some simple information about the consumer’s identity, account balance, credits or debits based on their CDR data. Accredited data recipients (ADR) must also apply the data minimisation principle in rule 1.8 of the CDR Rules when disclosing CDR insights. This means that an accredited data recipient must not use or collect a consumer’s data beyond what is reasonably needed to provide goods or services, and only disclose the minimum data required to provide the consumer with the relevant service. What will be considered a CDR insight will depend on the specific use case. While BSB and account numbers may not be considered sensitive information, our view is that disclosure of raw BSB/account numbers may go beyond what is needed to verify a consumer’s identity (in circumstances where an ADR may be able to instead match separately provided BSB/account numbers and verify a consumer’s identity with a ‘yes' or ‘no' response). See the OAIC guidance on CDR insights for more information. |
| 2273 | Further clarification on bundle product requested Based on the CDR definition of product bundle - https://cdr-support.zendesk.com/hc/en-us/articles/360004276695-Definition-of-a-Product-Bundle The existing guidance suggests that - The term ‘bundle' is not defined in the rules. Therefore, expect the term to be interpreted in the context of specific commercial offerings. While the term ‘bundle' is not defined in the rules, the definition of 'product specific data' in CDR Rules, Schedule 3, section 1.3; and Schedule 4, section 1.3, includes ‘bundles’ as an example of 'features and benefits' used to identify or describe the characteristics of a product or plan. We do not have any product bundle offerings in true sense (Bundled Offering), all we have are two products marketed in product web pages that informs the customers about the bonus interest if they had two products together. Customers cannot buy the bundle neither there was a contract for this bundle and they have a free choice not to have two products. But there is a bonus rate applicable for customers who meet each product criterions if they have both the products. Like, the special bonus interest is applicable only when the Home Saver Account balances up to $100,000 (the proportion of your account balance over $100,000 will earn the base rate of interest). We determine whether you're eligible for bonus interest by looking at the deposits made into your Everyday Account/s during the month. Each month a total of $2,000 (or more) needs to be deposited via electronic transfer from a account we dont own into your Everyday Account/s. So, as a DH we feel that this is not a bundled product. Question is - Should this scenario be considered as a bundle offering from the CDR perspective just because we use the bundle word in our product webpages from SEO perspective? |
As you have noted, the CDR Rules do not provide a specific definition of a ‘product bundle’ Definition of a Product Bundle. While the description of a combination of products as a ‘bundle’ by a data holder is not determinative, where a ‘feature or benefit’ is offered to a consumer as a result of combining products, this is more likely to be considered a bundle for CDR purposes. The knowledge article states packaged products and plans (often involving discounts to the consumer) are common examples of features and benefits likely to be considered a bundle. We expect data holders to take a pragmatic view of the word ‘bundle’ and a product’s features/benefits in line with the purpose of the product data sharing obligations. This is to ensure consumers have access to accurate, up to date and complete data about the benefits and features of products offered by data holders. Where combining (or bundling) products provides consumers with additional benefits and/or features beyond what would apply to a singular product, we would generally expect data holders to provide this information as ‘product specific data’ in response to a product data sharing request. For completeness, we note that ‘discounts and bundles’ appear as non-exhaustive examples of ‘associated features and benefits’ in the definition of ‘product specific data’ in clause 1.3 of Schedule 3. Therefore, while product specific data may not strictly relate to either a discount or a bundle, it could still be captured as product specific data in the CDR if it relates to an associated feature/benefit of a product. |
Attendees are invited to raise topics related to the Consumer Data Right that would benefit from the DSB and ACCCs' consideration.
View a number of informative and useful links in the Consumer Data Standards Guide on Information Links.
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