Note: This article is out of date and has been archived.
For the latest information, please see article on authorisation and consent.
Archived Text
Questions
Can we please confirm our assumption of how an active consent would be treated following the death of a customer:
- Where a customer dies, their CDR consent expires and no further data sharing should take place.
- Where a customer dies and they have a joint account, the account ownership reverts to the other living account holders.
(a) If the deceased customer was the requester/initiator of the CDR consent, the consent expires and no further data sharing should take place.
(b) if the requester/initiator of the CDR consent is one of the remaining living account holders, the CDR consent continues unaffected.
Answer
The rules don't directly specify what happens when a CDR consumer dies. To some extent, the effect of a customer dying will depend on the data holder's practices in relation to the customer's accounts. We are not able to review and comment on all data holders' practices.
However, our assumption is that generally the consumer would no longer qualify as an eligible CDR consumer, which would cause their authorisations to automatically expire (Rule 4.26).
Comments
2 comments
"However, our assumption is that generally the consumer would no longer qualify as an eligible CDR consumer, which would cause their authorisations to automatically expire (Rule 4.26)"
Therefore is it safe to assume that the the remaining living account holder would no longer be eligible and that they would be required to proceed with a new consent, in order to become eligible for data sharing ?
This article seems to be ambiguous or conflicts with another related to ineligible accounts.
The assumption above is that when a participant dies they become ineligible, however ineligibility is outlined in the other article as a revocation (not an expiration). Should the Holder be sending notifications (via the ADR) to a dead person?
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