Clarification on closing an account

Question

From a Data Holders perspective what is the expectation for a customer that only has one account which is in a sharing arrangement with an ADR (or multiple ADRs)?

When a customer closes this account (which could potentially mean they lose their online banking access), does this action:

• terminate the existing sharing arrangement(s) as customer is technically no longer eligible (they don't have active accounts with the DH, nor are their accounts set up in a way that they can be accessed online) ?
• require the DH to continue responding to data requests even after the account and the relationship is closed, until the consent/authorisation is withdrawn explicitly?

Answer

As the definition of an eligible customer in the Rules for the Banking Sector is for customers with at least one online account then the scenario you articulated would appear to make them ineligible.  It is the expectation of the Data Standards Body that any arrangements in place for a customer that becomes ineligible should be treated as being revoked and should be actioned accordingly so that the ADR can clean up the CDR data previously shared according the customer's election.