ADR actions on DH status change

Question

What actions should an ADR take when the status of a Data Holder changes from Active?

Answer

There is no specific guidance on this. It is entirely up to the ADR (Accredited Data Recipient).

Any consent authorisations related to the DH cannot be used while the Data Holder (DH) is inactive. The ADR may wish to convey this to the consumer in their dashboard or elsewhere, as appropriate to the ADR service.

The ADR may want to retain the consents related to the DH, in case the status change is temporary. Depending on the situation, however, the consents may be broken when the DH returns to active status.

The main reasons for DH status change are likely to be merger or acquisition. A manual transition of ongoing consents may be required if a DH merges with another DH.