Where Data Holders support logical ‘sub-accounts’ for customer-defined ‘goals’ that allow funds within the account to be ‘transferred’ to goals on a scheduled, ad-hoc or rounding basis, should these intra-account ‘transactions’ be included for data sharing?
The types of CDR data in scope for the banking sector are listed in clause 1.3 of Schedule 3 to the CDR Rules. This includes transaction data which is information that identifies or describes the characteristics of the transaction and account data which is information that identifies or is about the operation of the account.
Where amounts are transferred to sub-accounts on a scheduled, ad-hoc or rounding basis, this data may be considered ‘transaction data’ under clause 1.3(3) as each sub-account can be considered to be an account for CDR purposes. These amounts could also be considered account data under clause 1.3(2) if there is an ongoing scheduled payment as this would be considered scheduled payment data. We do not consider that these amounts would be customer data under clause 1.3(1).
The CDR Standards also support intra-account transactions being included for CDR data sharing. Under the non-functional requirements, there are data quality standards to ensure that consumers receive a commensurate experience via the CDR as they do within their existing digital banking channels. That is, if the transactions are visible to customers in their existing digital banking channels, the expectation is that they should be shared via CDR.