Management of non-active customer CDR request

Question

The Energy sector has additional eligibility criteria for Consumer Data Right (CDR) consumers which state that "they should be current customers of the retailer, who is deemed as the primary Data Holder (DH)".

In accordance with the Consumer Data Rules 2.1 additional criteria for customer eligibility for the energy sector. Specifically, for sub-rules 1.10B(1) and (2), the additional criteria for a CDR consumer to be eligible, in relation to a retailer at a particular time are:
(a) the CDR consumer is a customer of the retailer in relation to an eligible arrangement; and
(b) the account relates to the arrangement.

For this clause, an eligible arrangement is an arrangement that relates to one or more connection points or child connection points for which there is a financially responsible market participant in the National Electricity Market.

Considering this, clarification is sought on which one is the recommended option for scenarios where, a DH gets a data request from an Accredited Data Recipient (ADR) for someone who is not currently an active customer, i.e. A past customer that currently doesn’t have an active energy contract with the DH.

Option 1
During the authentication step, check if the customer is active (via customer ID, account ID etc), If not then send an error message to the ADR.
Option 2
Complete the authentication and OTP process if the email orphone held by the DH is valid, and on the dashboard do not show any accounts as eligible for CDR data sharing, as the customer is not currently active with this DH.
Option 3
Up to DH’s discretion in terms of which option (1 or 2) they want to proceed with.  

Answer

For the Banking sector and in cases where a customer is deemed as ‘ineligible’ according to the Rules, the DH is not obligated for sharing any data. Furthermore, if previous consents are in place and a customer ceases to be eligible, then those consents should be revoked.

The applicability would be the same to the Energy sector.

See: Clarification on Closing an Account