These questions relate to CDR Rules, Schedule 3, Part 4 Joint Accounts, Subdivision 4.3.2, section 4.12 Continuation and removal of approvals.
Can you clarify the terms approval, disclosure option. authorisation and Joint Account Management System (JAMS)?
'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 ADR (Accredited Data Recipient) 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 joint account management service (JAMS) is concerned with a consumer's disclosure options. This can exist on a consumer's dashboard but provides a separate function to the consumer dashboard itself, which primarily deals with a consumer's authorisations (i.e. authorisation management).
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.
- CDR Rules, Schedule 3, Part 4 Joint Accounts, Subdivision 4.3.2, section 4.12 Continuation and removal of approvals.