Data sharing when a previously ineligible customer becomes eligible

This article was updated on 20 June 2024 to include references to the relevant Rules and additional information on the data sharing obligations in relation to consumers who become eligible CDR consumers. 

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

Yes, a customer who becomes eligible for the CDR when they turn 18 years of age (and meet all other eligibility requirements) may share transaction data from the relevant account for the past two years. 

This is because under the CDR Rules, transaction data is required consumer data for transactions that occurred within the previous 7 years (see clause 3.2(4)(a) 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 in response to a valid request dating back 7 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 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.