Question
When a Secondary User Instruction is approved by a Joint Account Holder, does this mean the Secondary User is then acting on behalf of that Joint Account Holder only, or for all Joint Account Holders?
Answer
Secondary users (with an instruction) can share data related to the joint account. Secondary users are not equivalent to a Power of Attorney so are not sharing on behalf of another joint account holder
Question
Should the Secondary User Instruction show the Secondary User status as approved to share data from the Joint Account for all JAHs, or only on the dashboard of the approving JAH?
Answer
All joint account holders are to be provided with a service that can be used to make or withdraw a secondary user instruction.
Question
Can all Joint Account Holders revoke the Secondary User Instruction?
Answer
Yes, as above.
Question
If a Secondary User Instruction is approved by a Joint Account Holder who has been identified as vulnerable what does this mean in relation to sharing approval notifications and dashboard updates for other JAHs?
Answer
This is for the Data Holder to determine based on their existing procedures.
Question
Does the Secondary User inherit the vulnerable status of the approving JAH for those joint accounts that the vulnerable JAH has approved the Secondary User to share?
Answer
As above, this is for the data holder to determine.
Question
Is it acceptable to prevent secondary user instructions from being approved for joint accounts by vulnerable joint account holders?
Answer
The rules allow Data Holders to refuse the disclosure of data in certain instances, and the Data Holder is not liable for a failure to comply with certain aspects of the joint account rules, if it is considered necessary to prevent physical, psychological or financial harm or abuse. We do not believe this extends to preventing the approval of secondary user instructions but this is a DSB interpretation, and as such should not be considered a legal or rules perspective.
Question
Are there any planned CX Guidelines that might clarify the complexities in relation to Secondary Users, Joint Accounts and vulnerable Joint Account Holders?
Answer
We are not planning to develop CX Guidelines for these specific scenarios given the intention of the rules is for this to be left to the data holder space
Question
If sharing permission for a Joint Account is removed via DOMS while the Joint Account is included on an active sharing arrangement sharing of data from that account is stopped on the active arrangement.
Answer
If a joint account is changed to a non-disclosure option, joint account data will stop being shared for all active arrangements that are associated with that joint account. The approval remains in place if the joint account holder did not withdraw the approval for specific authorisations, but the non-disclosure option takes precedence.
Question
If sharing permission is subsequently re-instated on the account and the initial arrangement is still active does data sharing automatically recommence for the Joint Account or does it need to be re-authorised via an ADR Amending Consent?
Answer
As above, if the approval has not been withdrawn for specific authorisations, and those authorisations remain active, then joint account data will recommence being shared when that joint account is changed from a non-disclosure option to an option that allows sharing again.
Question
Similarly for a Secondary User account, within a Secondary User authorised arrangement, where the SU account permission is revoked and re-instated - does data sharing automatically recommence for the SU account if the initial arrangement is still active?
Answer
Yes, similar to what occurs for joint accounts. This is because changing to a non-disclosure option and withdrawing a secondary user instruction stops data being shared from the relevant accounts, but does not withdraw the authorisation(s) those accounts were associated with.
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