Providing dashboards to nominated representatives acting on behalf of CDR consumers

Question

Where a CDR consumer is a non-individual or partnership, and an individual has been made a nominated representative to authorise and manage consumer data sharing on the CDR consumer’s behalf, who must the data holder provide a consumer dashboard to?

The ACCC guidance on nominated representatives, non-individuals and partnerships in the CDR confirms the ‘CDR consumer’ is the actual non-individual or partnership, not the nominated representative. While only nominated representatives can manage authorisations, data holders have an obligation to provide the ‘CDR consumer’ with the consumer dashboard under rule 1.15. Does this mean there is a requirement to provide a “view only” consumer dashboard for partners of a partnership, or individuals linked to a non-individual CDR consumer, who are not nominated representatives?

Answer

Data holders are required to provide a consumer dashboard to the non-individual or partners in the partnership (the CDR consumer), which its nominated representatives would be able to access and use to manage data sharing (see rule 1.15(1) and (2A)). Providing a dashboard to a nominated representative would satisfy the requirement to provide the dashboard to the relevant CDR consumer.

Only nominated representatives can use the dashboard to manage authorisations. While a data holder may provide ‘view only’ dashboards to non-individuals or partners in a partnership who are not nominated representatives to enable them to obtain an overarching view of authorisations, our view is that this is not required to satisfy rule 1.15.