Submission on the proposed business purpose consent for the consumer data right
The professional accounting bodies support the proposed business purpose consent and recommend that the consent be available to all consumers.
In brief
- Disclosure for business purposes should be available to all consumers
- We support extending the duration for business purpose consents for up to 7 years
- We recommend the host of CDR data must retain a record of the business purpose statement
In the submission, the professional accounting bodies support the addition of a business purpose consent and for the duration of the consent to be up to 7 years.
The proposal seeks to introduce a business purpose disclosure consent for business consumers only. Business consumers are defined as not an individual or holding an Australian Business Number (ABN). The underlying premise for the proposal is that a business is more likely to have existing relationships with service providers and have data security and data sharing procures in place.
In our submission, we challenge this underlying premise noting that to incorporate a business you simply have to be over 18 years of age and, to obtain an ABN, be carrying on or starting an enterprise. Therefore, we do not consider a business consumer to have a higher level of literacy around data security or data sharing.
We continue that, for our members, their clients seek their services for all their affairs, both personal and business. Therefore individual consumers are just as likely as business consumers to have established relationships with service providers. Further, owners of small businesses, and holders of ABNs, often rely on the data security and data handling literacy of their service provider.
Finally, we raise absent from the proposal is a requirement for the host of the data, the accredited data recipient, to make and retain a record of a business purpose statement which effects a business purpose consent. We consider this critical for consumer protection as, if this consent is adopted, it can be in place for up to 7 years.
We support the introduction of a business purpose consent and that such a consent can be in place for up to 7 years. We advocate for a business purpose consent to reflect the purpose only and be available to all consumers.
Statutory review of the consumer data right
The joint accounting bodies are concerned that the CDR framework undermines consumers’ control of their data.
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