How can account holders make, withdraw and manage secondary user instructions?
Rule 1.13(1)(e) applies where a person has account privileges in relation to an account. It requires a data holder to provide a service to an account holder that they can use to make or withdraw a secondary user instruction. This service may be provided online or offline.
Rule 1.15(5) applies where a person is a secondary user for an account (i.e. where a secondary user instruction is in place). It requires the data holder to provide an online service to the account holder with functionality that includes the ability to withdraw a secondary user instruction (rule 1.15(5)(b)(ii)).
While rule 1.13(1)(e) permits a data holder to provide an account holder with the ability to make or withdraw a secondary user instruction online OR offline, rule 1.15(5) requires data holders to provide online ability to withdraw a secondary user instruction (r 1.15(5)(b)(ii)), once there is a secondary user on an account. This being the case, we encourage data holders to provide online functionality from the outset, in addition to any offline service that may be provided. Facilitating the withdrawal of a secondary user instruction through an online service will satisfy rule 1.13(1)(e)(ii) and rule 1.15(5)(b)(ii).
Finally, we note that if the data holder provides a consumer dashboard to an account holder, rule 1.15(7) requires that the functionality referred to in rule 1.15(5) is included in the account holder’s consumer dashboard.