Data sharing on closed accounts

Question

For a data holder, as per this article on the CDR Support Portal, when a customer closes the only account they have with a data holder, they cease to be an ‘eligible’ CDR consumer for the purposes of the CDR Rules (Schedule 3, clause 2.1 [banking] and Schedule 4, clause 2.1 [energy]), and all existing authorisations to disclose consumer data expire.

What happens when the customer has multiple open accounts with the data holder and only closes one of their accounts?

Answer

Where the customer has multiple open accounts with the data holder (DH) and closes one of their accounts, the authorisation for the closed account does not immediately expire (as it would by operation of Rule 4.26(1)(c)). This is because the CDR consumer remains an eligible consumer (as defined in Schedule 3, clause 2.1 and Schedule 4, clause 2.1). The DH is therefore authorised to disclose the CDR data that was the subject of the authorisation, even if it includes CDR data from a closed account (Schedule 3, clause 3.2, note 3 (banking) and Schedule 4, clause 3.2, note 2 (energy)).

However, whether the DH is required to provide CDR data from the closed account in response to a consumer data request depends on whether the data requested is ‘required consumer data’. To determine this, see Schedule 3, clause 3.2 for banking and Schedule 4, clause 3.2 for energy. In addition, if Schedule 3, subclause 3.2(5) or Schedule 4, subclause 3.2(6) applies to the data, it is ‘voluntary consumer data’ and the DH may choose to disclose the information (i.e. it is not compulsory to do so).