Clarification on Data holder providing link to CDR policy

Note: the below FAQ represents a point in time, as suggested the CX Guidelines will be updated to reflect the changes

Question

According to this rule, a Data Holder (DH) will need to include details of the complaints process on the Consumer Data Right (CDR) policy.

The question is at which stage (wireframe) is the CDR policy expected to be shown on Data holder side.

As per the CX guidelines, the CDR policy is only visible on the Data recipient Consumer dashboard as above.

Answer

Rule 7.2(8), in division 7.2, states that CDR participants must make their CDR policies readily available through each online service they ordinarily use to deal with CDR consumers.

'CDR participant' refers to both ADRs and DHs, but it is true that the CX Guidelines only show an example of the CDR policy on an ADR dashboard.

We would consider the authentication step to be a reasonable place to surface the CDR policy as this will likely be the first online service the CDR consumer uses to interact with their DH for CDR.

We would also consider the authorisation flow to be an appropriate context for the CDR policy, along with the data sharing arrangement on the DH dashboard.

All of the above examples are reflected in the live implementations of real-world CDR participants.

The next release of the CX Guidelines will be augmented with the above examples in mind.