Acting for one of Australia’s largest credit unions on all aspects of its roll-out of Consumer Data Right compliance obligations, in its capacity as a data holder.

Consumer Data Right is a relatively new regulatory compliance obligation with a rapid agenda for phased roll-out, in terms of data scope, types of accounts captured, and authorities to share data. This requires interpretation of complex, constantly evolving, and often vague and inconsistent requirements under the new legislation, rules, and data standards.

Spanning several months to date, the project has required extensive engagement with cross-functional teams, to advise on compliance in the context of operational processes and constraints. Advice has been provided with respect to a raft of complex, and often difficult to interpret, requirements under the various documentation, which constitutes the Consumer Data Right regulatory landscape. This includes advising on the technical and consumer experience standards, which form the Consumer Data Standards, and which evolve on a continuous basis.

Embedded in the cross-functional review team, a broad scope of assistance has been provided including on the interpretation of requirements and their articulation for the technology supplier; review of process maps to underpin business processes; review of wireframes and notification templates; advice relating to the privacy safeguards and the CDR policy.

In addition, we were able to assist to ensure the smooth transition of Consumer Data Right registrations on the Consumer Data Right Register, and compliance obligations at entity and brand level in the context of a merger. This required extensive regular liaison with the operational and technical teams at the regulator, as well as between the merging entities to ensure an integrated and aligned approach was adopted.

Due to the complexity of the Consumer Data Right obligations, most data holders have, at any one time, a number of implementation gaps, which must be noted on the ACCC Consumer Data Right public rectification schedule. Over several months, we have advised on the drafting of regular rectification reporting to the ACCC, and co-ordinated stakeholders to ensure relevant information is captured and accurately reflected.

We continue to work to support this client in respect of the ongoing implications of merger, and to advise in relation to future anticipated Consumer Data Rig