Consent on closed accounts

Question

What are the expectations of the ACCC in the scenario where the customer of the data holder (DH) ends their relationship with the bank but has an active consent? Customers typically lose access to eBanking when they have no active accounts. In the scenario mentioned this means that the customer will cease to have access to their DH dashboard. In fact, they will cease to be an eligible customer with respect to Consumer Data Right (CDR) for the DH (or does that only apply to creating consent?). 
They will, of course, still have access to their accredited data recipient (ADR) dashboard to revoke consent. We would welcome any comment/feedback on this.

Answer

Where a customer of a DH bank closes all of their accounts with the DH, the customer will cease to be an ‘eligible’ CDR consumer for the purposes of the CDR Rules (Schedule 3, clause 2.1). This has the consequence that all existing authorisations to disclose given by the customer to the DH will expire (see Rule 4.26(1)(c)). At this point, there will be no authorisations relating to that DH for the customer to manage and so the obligation under Rule 1.15 to provide a consumer dashboard will be extinguished in respect of that DH (at least until the customer opens a new account with the DH). As such, where a customer closes all of their accounts with the DH, there is no expectation that the DH will provide the customer with dashboard access for any longer period than the customer would ordinarily have access to online banking services after closing all of their accounts.