Consumer Data Right (CDR) co-regulator the Australian Competition and Consumer Commission (ACCC) has relayed stakeholders’ concern over “significant shortcomings” in the quality of the scheme’s product reference data, noting that accredited data holders are failing to conform to CDR standards.
The ACCC – as part of a two-month consultation surveying CDR data users – found that a majority of accredited data holders encountered quality issues with product data, with the regulator noting particular concerns with the publishing of incorrect interest rates.
Product reference data refers to publicly available information concerning a data holder’s products, including, for banks, comparable datasets on home loans, savings accounts, and credit card products.
The competition regulator warned that data holders’ provision of data of insufficient quality can have a significant adverse “impact on the reputation of data recipients who attempt to use that data”.
“Some data recipients reported that where poor data quality results in poor service, they may be subject to poor customer reviews, on the assumption the recipient caused the issue.”
In addition to product data, stakeholders also signalled concerns with the inconsistent quality of consumer data, the inadequate response of data holders to recipients with data quality concerns, a poor understanding of data quality obligations, issues and causes by CDR participants, and a demand for CDR scheme regulators (the ACCC and OAIC) to take a stronger regulatory approach to improve data quality.
The ACCC notes that, over the three-week consultation period, more than 280 separate data quality issues were raised by stakeholders relating to data holders. The consultation also included an additional one-month bilateral meeting period with CDR stakeholders.
Poor product data quality, the regulator stressed, ultimately hinders reliable product comparison, and makes it “difficult to use this data as a basis for a consumer-facing product or service”.
It also breaks a core rule (4.13) of the CDR scheme to supply a product data disclosure service, as well as a requirement that any information included on a data holder’s website or in a product disclosure statement also be made available through the scheme for product comparison.
In an effort to improve product data quality, the ACCC said it will work with Treasury, the Office of the Information Commissioner (OAIC), and the Data Standards Body (DSB) to develop new guidance on data quality-related obligations, and to consider clarifications to particular data quality-related obligations in the CDR framework.
The ACCC will also look at options to improve the participant experience, it said, for instance, “publishing information about data holder implementations so that data recipients can develop use cases accordingly”.
Data recipients in the CDR scheme also identified continuing instances of encountering poor-quality consumer data; however, stakeholders noted that consumer data quality had improved over the period since the CDR commenced.
Overall, stakeholders assessed CDR data as of “significant value and generally sufficient to support the delivery of CDR products and services”.
“Data recipients are providing services to consumers, and many data holders have become accredited data recipients and are likewise developing use cases.”
The ACCC said it will move to increase its enforcement of data quality non-compliance by accredited data holders, specifically relating to: incorrect interest rates in product reference data; information shared in free text fields, rather than relevant structured fields; missing or incomplete data; instances where data provided is not commensurate with what a consumer can otherwise see in their online or mobile banking channels; and instances where there are slow or insufficient responses to data quality issues.
The regulator said it will also move to improve the Service Management Portal through which stakeholders can raise data quality issues.
“This may include implementing service level objectives to improve response times on tickets, and reviewing incident types and trends to ensure data quality incidents are appropriately tracked,” it said.
In a bid to further promote CDR compliance, the ACCC said it may also move to publish known issues with product reference data relating to individual data holders and to explore opportunities for a dedicated channel through which users of product reference data can raise issues directly with data holders.