Playing with Data within Consumer Data Right(CDR) Boundaries
CDR covers multiple industry sectors, not only banking. For each industry the designation instrument defines the data. For banking sector (Authorised Deposit-Taking Institutions) data scope covers (1)product, (2)product usage and (3)user of the product as shown below.
Materially Enhanced Information (Derived Data)
Additionally, CDR designation instrument talks about the concept of “materially enhanced information”. Materially enhanced information are information generated based on usage of product(s) using analytics and insight as shown below. A eco system player can make the information significantly more valuable than the source material in terms of usefulness, usability or commercial value by materially enhancing the CDR data.
Examples of ‘materially enhanced information’ in the banking sector include the findings of an income or expense assessment, and a categorisation of transactions as being related to groceries or rent.
Based on the designated instrument the following information is not materially enhanced information:
(a) a calculated balance
(b) an amount of interest earned or charged
(c) a fee charged
(d) a reference number, including a routing number, a clearing house number or a swift code
(e) information identifying a person, body, product, transaction or account
(f) the categorisation of source material based on a feature of the product to which it relates, including categorisation by the fees or interest rates applicable to the product
(g) date, period or amount
The Designation Instrument has responded to concerns raised during the consultation about the scope of Product Use Data by excluding “materially enhanced information” from the Open Banking regime as shown below.
Materially enhanced information provide a path to build a personalised, predictive, and actionable insights delivered in real-time to each user through the bank’s digital applications by combining it with additional user-specific data streams (including relationships, transactions, location, and behaviour).
These personalised insights include:
- Unusual account activity which may require an action (e.g. annual subscription renewal, unrecognised merchant charge)
- Spending patterns (e.g. how much I’m spending on dining out)
- Potential upcoming issues and actions I can take (e.g. insufficient balance prediction)
- Ways to avoid potential fees & penalties (e.g. what card to use out of the country)
- Services that would benefit me and simplify my banking (e.g. overdraft protection, automated payments)
- Offers relevant to my behavior, actions, and location (e.g. Foreign currency account for travelers / cross-border transactions)
- Personal advice to improve my finances (e.g. how to save more based on my cash flow patterns)
References
- What is CDR data — OAIC
- CDR for ADI’s designation 2019 — Federal Register of Legislation
- Consumer Data Right Open Finance Sectorial Assessment
