Data sharing when a previously ineligible customer becomes eligible

This article was updated on 28 August 2025 to align with CDR Rules on data sharing obligations in relation to transaction data. 

Question

If a customer, who has been ineligible for data sharing, becomes eligible, should the transaction data, for the period when the customer was ineligible, be shared with Accredited Data Recipients (ADRs) upon request?

For example, a customer who has been with the bank for two years is initially ineligible for data sharing as they are under 18 years of age. Once the customer turns 18 years old, they become an eligible CDR consumer after satisfying the relevant eligibility criteria. Is the customer able to share their transaction data from the past two years given that the data was collected when the customer was under 18 years old?

Answer

A customer who becomes eligible for the CDR when they turn 18 years of age (and meets all other eligibility requirements) may request the sharing of transaction data from a relevant account. This includes data related to transactions that occurred before the consumer met the eligibility requirements.

Under the CDR Rules, transaction data is required consumer data if the data relates to transactions on an open relevant account that occurred 2 years ago or less (see clause 3.2(2), and 3.2(6) of Schedule 3 to the CDR Rules). A data holder must disclose required consumer data in response to a valid request from an accredited person, subject to rules 4.6A and 4.7.

Once a customer becomes an eligible CDR consumer, the data holder must provide transaction data from an open account in response to a valid request for transactions dating back 2 years from the current date. This includes relevant data collected prior to when the consumer met the eligibility requirements. Data holders can choose to provide a longer period of transaction data, or transaction data from a closed account, as voluntary consumer data. 

 

Previous text

Question

If a customer, who has been ineligible for data sharing, becomes eligible, should the transaction data, for the period when the customer was ineligible, be shared with Accredited Data Recipients (ADRs) upon request? For example, a customer who has been with the bank for two years, ineligible for data sharing, turns 18 and becomes eligible. Is the transaction data for the past two years eligible for data sharing?

Answer

Yes.