CDR participant complaints process

Question

Do we need to extend the existing customer complaints process to accommodate CDR participants complaints (item 2.7 - product data reporting)?

Answer

Currently there are no internal dispute requirements specified in the CDR rules for the handling of CDR participant complaints in relation to product data requests, so there are no formal obligations for the data holders (DHs) to extend their existing customer complaints process to accommodate CDR participant complaints under the rules. What may need to be implemented, however, is a system for recording the number of complaints that come in from other CDR participants so they can report on these under item 2.7.