Question
An accredited data recipient (ADR) is required to keep and maintain records that record and explain ‘the collections of CDR data’ under rule 9.3(2)(e).
What does ‘collection of CDR data’ mean?
Is it the actual data the ADRs have collected over time or something else?
Answer
For the purposes of recording the ‘collection of CDR data’, we expect ADRs will maintain 'collection logs' evidencing the type of CDR data that was collected, when the CDR data was collected (including time and date) and the relevant DH of the CDR data. We do not expect ADRs to keep copies of disclosed CDR data itself, and records should not include personal information unless it is necessary to do so to comply with the CDR rules.
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