[ARCHIVE] ADRs using SaaS Solutions

Note: This article is out of date and has been archived.

Changes were made to the outsourced service provider (OSP) rules as part of the Competition and Consumer (Consumer Data Right) Amendment Rules (No. 1) 2023. For guidance and information on OSPs see factsheet on CDR outsourcing arrangements, CDR outsourcing arrangement: privacy obligations for an outsourced service provider published by the OAIC, and the latest version of the CDR Rules.

Archived Text

Question

If an ADR uses a non-exclusive SaaS licence as a cloud- based solution, where should systems and data storage sit; in the ADR cloud account or a third-party cloud account? 

Answer

The ACCC published advice in a newsletter on the use of SaaS, https://mailchi.mp/accc.gov.au/minor-rules-amendments-exemptions-granted-white-label, see heading "ACCC position on utilising software to collect Consumer Data Right data", our position remains unchanged since this advice was issued. 

If further clarification is needed we recommend seeking legal advice on the application of the rules in relation to SaaS.