Archived 2023.01.11. Content moved to Guidance on ID permanence
Partnership accounts are eligible to enter into the CDR regime only in November 2022. From this point onwards the CDR is open to non-individuals and secondary users.
Partnership accounts can be set up as a single entity, with a single account owner, or as a joint account with two separate entities owning the account.
An example of the single entity partnership account structure is Sam Smith and John Jones trading as Smith and Jones Law.
An example of the partnership joint account structure is Sam Smith as one entity, and John Jones as another entity, linked to the one account, that may be named Smith and Jones Law.
If a partnership account structure is a single entity, it is eligible for CDR data sharing in November 2022.
If the partnership is set up with a joint account structure, it is eligible for CDR data sharing from 1 July 2022 by default.
Is this a correct interpretation of the standards?
Yes, for the instances mentioned in the question, this is a valid interpretation of Data Holder obligations under the standard.