Reporting on Participant Complaints

Question

Are data holders required to include complaints they receive from other CDR participants in their reports to the ACCC and OAIC?

Answer

Rule 9.4(1)(b) of the CDR Rules states that a data holder must prepare a report for each reporting period that summarises the CDR complaint data that relates to that reporting period. Rule 1.7 sets out the definition of ‘CDR complaint data’ in relation to a CDR participant. The definition sets out that data holders must report specific data about complaints from CDR consumers and do not need to report on complaints received from other CDR participants, except in relation to product data complaints. Product data is data that does not relate to a particular consumer. Therefore, a data holder is required to report on product data complaints received from all parties, including CDR participants.