The CX Guidelines suggest that the following details have to be displayed on the data holder's dashboard, sharing arrangement's detail page:
- Access granted date for a particular account
- Initial data sharing date of a particular data cluster
However, the technical solution for Consent Amendment functionality requires that the data holder revokes the current consent and setup a new consent with new consent parameters and associated accounts keeping the cdr arrangement ID a constant.
With this requirement, both the access granted date (of an account) and initial sharing date (of a data cluster) would be reset to align with the new consent, even for the accounts and data clusters which were not amended. How do we resolve this conflict?
For clarity, the 'access granted on..' statement for a particular account is a CX recommendation but not a requirement. Displaying the initial sharing date for a particular data cluster is a requirement, as per rule 7.9 and Privacy Safeguard 10.
To deal with this issue, the DSB recommends displaying the details of the current authorisation on the dashboard, and providing a 'History' feature that allows the consumer to access past versions of the current authorisation. The 'past versions' would technically be expired authorisations link via the cdr_arrangement_id. Showing past versions allows previous account and data access details to be displayed.
The latest CX Guidelines for DH Dashboards mention a 'Consent history' feature, which can be found under 'Sharing period' near annotations 6 and 18.
The latest ADR Dashboard guidelines look at this potential feature in a little more detail - see the 'Amending consents' variation for how this could work for an ADR.
Importantly, ADRs are required to show the details of amendments, but DHs are not. This is because, as you noted, amended authorisations are technically revoked, while consents are legally considered to be 'amended'. Consequently, the ADR's 'Consent history' may differ in that it may not refer to expired consents in the same way a DH's 'Consent history' would.
While DHs are not required to display 'amendments' like ADRs, DHs who are also ADRs may want to consider this functionality to establish greater consistency between their DH and ADR dashboard views.