What transaction time should a Data Holder (DH) provide in a case where the DH does not have the time of transaction available and it is not presented to customers in online banking or on statements?
This is up to the Data Holder. The recommendation is to pick a time (e.g.
00:00:00 and use that time consistently for all situations that meet these conditions.
What is the expectation in a case when a transaction time is captured as a system time on infrastructure which is not located in Australia?
DateTimeString allows for the specification of UTC time or a timezone based offset so all of these scenarios can be handled. The date time should be correctly according to the normative RFC so that the date/time can be correctly interpreted.
If some (not all) transactions are stored as the local system time in one time zone and are not shown in DH’s digital channels or on statements – are DH’s required to share these times, potentially creating an inconsistent experience?
Or would returning the value "00:00:00" be considered compliant, as the data presented via API would be commensurate to digital channels?
Times stored in local system time in a specific timezone can be easily represented using a DateTimeString as you can simply include the timezone information.