Data Holder’s consumer experience flow for the new sponsor affiliate model

Question

Under the new sponsor/affiliate model introduced by the ACCC, is a Data Holder (DH) sharing information with an affiliate required to inform the customer that the data is being collected by the sponsor on the affiliate’s behalf?

Alternatively, should DHs continue to display that they will only be sharing data with the ‘end user’ (affiliate) like any current data sharing request, rather than the sponsor?

Answer

No, there is no obligation for a DH to inform the customer that data is collected for an affiliate. A DH may not be aware of the affiliate or representative, because only an unrestricted Accredited Data Recipient (ADR), as a sponsor or principal, can collect data from DHs. 

The DSB published ADR CX Guidelines for new access models, see the relevant sections in CX Guidelines, CDR outsourcing, sponsorship and CDR representative arrangements.

There are no requirements for the DHs to change their CX flow. Proposals are being developed in relation to the various access models, however, which will be consulted on in Decision Proposal 229 when ready.