Consent with no attached accounts

Question

Can consent be active without any attached accounts?

Is it mandatory for a Data Holder(DH) to allow a consent with no attached accounts?

The CDR Rules Schedule 3, section 3.2(1), suggest this may be mandatory, as "customer data in relation to a CDR consumer" is in the category of required consumer data. The DH must disclose required consumer data in response to a customer request. 

However the CX Guidelines, in the section Authorise | Account selection, is not clear on what to do if no account is selected. The CX Guidelines seem to suggest consent may be omitted in this case.

Answer

Consent can be active without any attached accounts. Sharing requests can consist only of data clusters that do not involve accounts. For example, a CDR consumer may request their customer data only.

It is mandatory for a DH (Data Holder) to allow a consent with no associated accounts.

The CDR CX Guidelines, Authorise | Account selection section, refers only to the account selection step being omitted, where the requested data does not relate to accounts.

See:

• Latest CDR Rules, Schedule 3, section 3.2 (1), Meaning of required consumer data and voluntary consumer data—banking sector.
• CDR CX Guidelines, Authorise | Account selection