Question
Consider a Joint Account (JA) with three Joint Account Holders (JAHs). Joint Account Holder 2 (JAH2) has disabled data sharing for the JA using the Disclosure Option Management Service (DOMS). In accordance with the Consumer Data Standards (CDS), during the authorisation flow:
- Can Joint Account Holder 1 (JAH1) give consent on a JA, which is disabled for data sharing by JAH2? If yes, then is the DH required to send a JA data sharing approval request to JAH2 only?
- If now JAH2 does not approve the JA sharing request within the required date, can the DH remove this JA from the consent?
- If a DH is providing only the opt-out option to the JAHs, when in an event a JAH is authorizing a consent that includes JA, do we need to enable JAH approval flow for those JAHs who have blocked sharing?
Answer
- If JAH2 has disabled sharing for the JA (i.e. changed to a non-disclosure option) then data cannot be shared from that account by any of the JAHs.
- This account would potentially appear as an unavailable account in the authorisation flow for all JAHs, and would not be selectable for sharing at this point. As such, it would not trigger an approval request flow via the authorisation flow as would occur in the DOMS.
- For any of the JAHs to re-enable sharing for that account again, all the JAHs would need to agree. This would trigger an approval request flow via the DOMS.
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