Joint accounts - removal of approvals

Question

These questions relate to CDR Rules, main section, part 4A, Joint Accounts, subdivision 4A.3.2, 4A.12 Continuation and removal of approvals.

Can you clarify the terms approval, disclosure option, authorisation and Disclosure Option Management Service (DOMS)?

Answer

Approval refers to how the authorisation itself is established, i.e. it may be 'pre-approved' or it may be 'co-approved'. When an approval is removed, it is as if a joint account has been removed from a specific authorisation. It will not stop joint account data being shared for other authorisations. Removing an approval will also not revoke the authorisation itself. Any joint account holder can independently remove an approval, regardless of whether a pre-approval or co-approval disclosure option is in place.

Disclosure option refers to the method of approval - or a preference to not approve of any data being shared - for a specific joint account. This is set at the account level and not at the Accredited Data Recipient (ADR) level or on an authorisation-by-authorisation basis.

Authorisation refers to the data sharing arrangement, i.e. the authorisation to disclose data to an ADR. A consumer may choose to disclose data from selected accounts as part of this authorisation, but the concept of 'authorisation' is separate to the concepts of 'approval' and 'disclosure option'. The initiating joint account holder (AH-A) can revoke the authorisation they established. The other joint account holders cannot revoke the authorisation - they can only remove the approval to disclose the joint account's data for that authorisation (i.e. remove the joint account from the authorisation).

The Disclosure Options Management Service (DOMS), previously called joint account management service (JAMS), is discussed in the CDR Rules, main section, part 4A, division  4A.2, 4A.6 Obligation to provide disclosure option management service. The DOMS can be part of a consumer's dashboard. It provides a means of changing disclosure options and informing  joint account holders of changes. 

Changing a disclosure option may have an impact on the joint account data being disclosed, depending on which option is chosen. The current consultation on joint accounts touches on this point.

Revoking an authorisation would have the effect of removing the approval for that specific authorisation, but this does not change the disclosure option associated with the joint account.

See:

• CDR Rules, Schedule 3, Part 4 Joint Accounts, Subdivision 4.3.2, section 4.12 Continuation and removal of approvals.