Requirement for records to be kept or maintained for 6 years

Question

Rule 9.3 requires CDR participants to keep and maintain a variety of records. Rule 9.3(5) requires these records to be “kept for a period of 6 years beginning on the day the record was created”. Can further information be provided on when the requirement to keep a record commences? 

For example, if an authorisation was provided on 1/12/20 and then an amendment was made on 1/12/21, are data holders required to keep a record of the authorisation until 1/12/26 and a record of the amendment record until 1/12/27?

Answer

Rule 9.3 requires CDR participants to keep and maintain records that record and explain certain matters. For data holders, this includes (amongst other things) both authorisations given by CDR consumer to disclose CDR data and amendments to authorisations to disclose CDR data. This means both of these types of records must be kept for a period of 6 years beginning on the date the record was created.

For example, records that record and explain an initial authorisation made on 1 December 2020 would need to be kept and maintained for 6 years from 1 December 2020. Records that record and explain an amendment to that initial authorisation made on 1 December 2021 would need to be kept and maintained for 6 years from 1 December 2021. Further, it is expected that records that pertain to an amendment to an authorisation should also include some description of the original authorisation.