Offline accounts

Questions

1. Can a consumer share data from an account that is not set up for online banking (i.e. an 'offline' account)?

2. Do products that are not available for online banking have to be shared under product reference data (PRD) obligations?

3. If a customer is not able to access their account through an online channel, does that mean the relevant banking product is : in scope for PRD but out of scope for consumer data sharing?

Answers

1. Yes, provided the consumer is ‘eligible’ to make data sharing requests (see clause 2.1 of Schedule 3 of the CDR Rules), a consumer can make requests to share data from offline accounts.  To be eligible, the consumer must have at least one account that they can access through online banking.
   
   Where an eligible consumer makes a consumer data request, a data holder must disclose any ‘required consumer data’ that is the subject of that request.  This can include ‘account data’, whether or not the account can be accessed online (see clause 3.2 of Schedule 3 and in particular, Note 3 to that clause). Products that apply to offline accounts are still in scope for consumer data sharing, if the customer is eligible.  The definition of required consumer data includes ‘product specific data’ and it will include, for example, interest rate and terms and conditions for the product the consumer uses– this is how consumers will be able to share specific rates that apply to their account, as opposed to the generally advertised rate which would be captured in PRD.
   
   
2. Referring to the answer above, PRD in relation to a publicly offered, offline product is likely to be subject to the PRD obligations in Part 2 of the Rules. 
   
   Schedule 3, Clause 3.1 of the Rules defines 'required product data'.  While the data must be 'held in a digital form' to qualify, the product itself doesn't need to be available online. 
   
   
3. PRD in relation to a publicly offered, offline product is likely to be subject to the PRD obligations in Part 2 of the Rules. 
   
   Schedule 3, Clause 3.1 of the Rules defines 'required product data'.  While the data must be 'held in a digital form' to qualify, the product itself doesn't need to be available online.  
   
   Separately, it's important to note that products that aren't available through online banking may also be subject to the consumer data request obligations. 
   
   Provided the consumer is ‘eligible’ to make data sharing requests (see Schedule 3, clause 2.1), a consumer can make requests to share data from offline accounts.  To be eligible, the consumer must have at least one account that they can access through online banking. 
   
   Where an eligible consumer makes a consumer data request, a data holder must disclose any ‘required consumer data’ that is the subject of that request.  This can include ‘account data’, whether or not the account can be accessed online (see Schedule 3, Clause 3.2, and in particular Note 3 to that clause).