We supported most of the consent and operational enhancement amendments proposed in the consultation paper and sought an additional prohibition to bundling of consents.

We sought a prohibition on the bundling of consents to effect disclosure of data derived from CDR data to a consumers trusted advisers (TA). We considered that allowing data recipients to pre-select and bundle consents for the purpose of a TA disclosure consent will mislead a consumer into thinking that they must use the trusted adviser nominated, and pre-selected by, the data recipient.

This follows the advice received that data recipients:

• are not required to offer a TA disclosure service to a consumer for their trusted adviser
• can offer a TA disclosure service to a trusted adviser of the data recipient who will have a commercial arrangement with the professional advisor, and
• where a consumer has not previously nominated the TA at the time of giving a TA disclosure consent, the data recipient may take the selection of a TA during consent to be the nomination of the TA.

While it is accurate that a consumer must use a trusted adviser agreed to by a data recipient to transfer data through the CDR channel, it is not mandatory to use the CDR channel.

We expressed our deep concern of the potential for the proposed enhancements to further disrupt the established relationship between an accountant and their client when the client would like to use the CDR channel.