Question
Do data holders need to report on complaints from consumers about product data requests?
Answer
Under the current definition of ‘CDR complaint data’ in rule 1.7 and under rule 9.4, a CDR participant that is a data holder must report on the number of CDR product data complaints it received in the reporting period. While CDR product data complaints are not CDR consumer complaints, they are defined rule 1.7 as 'an expression of dissatisfaction made to a data holder about its required product data or its voluntary product data for which a response or resolution could reasonably be expected'. Any person, including a CDR consumer, can make a CDR product data complaint.
The example data holder reporting form (found under Forms and templates on the CDR website), in the 'CDR complaint data' section, asks data holders to:
1. Set out the total number of CDR complaints received relating to product data.
2. Set out the total number of CDR complaints received relating to consumers, or consumer data.
Complaints from consumers about product data requests should therefore be reported as CDR product data complaints, not CDR consumer complaints.
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