Are contractual arrangements required between an ADR and a DH to process and use the CDR data? Does the onboarding process cover all agreements an Accredited Data Recipient (ADR) would need to have with a Data Holder (DH), including PKI (Public Key Infrastructure) certificates?
For ADRs, no individual contractual arrangements with DHs are required to receive and use CDR data. ADRs should refer to the CDR onboarding process. Additionally, the Competition and Consumer (Consumer Data Right) Rules 2020 provide the framework for how the CDR operates.
Only persons wishing to become an ADR must apply for accreditation. ADR applicants are not required to share their consent management flows or any documentation regarding this process during the accreditation process. Currently, we request a link to the applicant’s CDR policy but this is not part of the assessment criteria for accreditation.