Consumer Data Right (Open Banking): Consent, Security, and Product Design
Understanding CDR
Australia’s Consumer Data Right (CDR) enables customers to safely share their data with accredited third parties to access better products and services. In banking (Open Banking), obligations sit across:
Data Holders (e.g., ADIs) who must share defined datasets via secure APIs;
Accredited Data Recipients (ADRs) who must obtain, manage and revoke informed, granular consent;
Privacy & security safeguards (e.g., consent dashboards, data minimisation, deletion/retention rules, incident handling);
CX standards and data standards that determine how consent, language and journeys are presented;
Product Reference Data (PRD) vs Consumer Data sharing, plus complex scenarios (e.g., joint accounts, secondary users, nominated representatives).
CDR now extends beyond read-access to emerging Action Initiation use-cases (e.g., payments, switching), raising expectations on controls, liability and customer experience.
Why CDR Matters
Done well, CDR unlocks competition, personalisation and switching while strengthening trust. For banks, platforms and fintechs, it is both a regulatory obligation and a growth lever:
Increases conversion through friction-light consent and reliable data;
Reduces complaints and remediation via transparent permissions and revocation;
Enables ecosystem partnerships (e.g., PFM, credit decisioning, switching) with clear accountability and evidence;
Supports conduct expectations by aligning data use with consumer understanding and benefit.
Key Implications for Firms
Granular consent (scope, duration, purpose) with clear dashboards and easy revocation;
Security-by-design (strong auth, encryption, API hardening, monitoring, incident playbooks);
Data minimisation & deletion rules embedded in pipelines, storage and analytics;
Operational readiness: uptime SLAs, error handling, outage comms, performance thresholds;
Joint-account governance (pre-approval models, notifications, exceptions);
Complaints & dispute handling aligned to IDR/AFCA where data sharing causes harm;
Evidence packs & MI that demonstrate compliance, consent lineage and control effectiveness to boards and regulators.
Key Challenges Facing Firms
Converting standards into production-grade APIs and consent UX that customers understand;
Stitching identity, consent and data lineage across legacy cores, data lakes and martech/analytics tools;
Managing partner and third-party risk (accreditation, sub-processors, data residency, onward disclosure);
Designing journeys that convert (plain-English prompts, progressive disclosure, contextual warnings) without breaching rules;
Handling edge cases (joint/secondary users, minors, vulnerable customers, business accounts);
Proving “use only what you need” with measurable data minimisation and deletion outcomes.
How OCG Can Help
Oceanic Consulting Group (OCG) turns CDR obligations into practical, defensible growth capability.
Target operating model & governance for Data Holder/ADR roles, RACI, policies and control libraries;
Consent & CX design: compliant language, dashboards, revocation flows, vulnerable-customer patterns;
Security & privacy engineering: identity, API security, telemetry, incident response, deletion/retention;
Data enablement: lineage, minimisation, access controls, audit trails, and analytics that respect permissions;
Third-party oversight: accreditation support, vendor due diligence, contracts, attestations and monitoring;
Assurance & MI: effectiveness testing, dashboards for boards/executives, and regulator-ready evidence packs;
Action Initiation readiness: risk, liability and journey design for switching and payments.
FAQs
What makes consent “informed and granular”?
Clear purpose, dataset scope, duration and who sees/uses the data, with simple pause/stop and delete options that actually work.
How does CDR relate to conduct obligations?
Consent and data use must match consumer understanding and benefit. Poor journeys or unclear purposes lead to complaints, breaches and remediation.
What evidence should boards see?
Consent volumes, revocations, exceptions, uptime/error rates, security incidents, deletion metrics, partner compliance status, and outcomes for vulnerable customers.
Strengthen Your CDR & Open Banking Programme
Work with OCG’s Data, Privacy & CX Specialists
Turn CDR into a competitive edge. We’ll design compliant consent and CX, harden APIs and security, govern data minimisation and deletion, and build MI and evidence packs that satisfy regulators while driving conversion and partnerships.
