NAB has warned the Consumer Data Right has characteristics that hinder rather than encourage innovation.
The major bank stated in its submission to the CDR statutory review in May [pdf] that while it sees “significant potential and consumer benefit in the CDR”, the current iteration could be changed to improve its innovation.
“We see significant potential and consumer benefit in the CDR and are committed to continuing to develop CDR-powered products and services, for the benefit of our current and future customers,” NAB stated.
“However, there are certain aspects of the current CDR settings and standards that have impeded our ability to innovate quickly and bring use cases to market in an efficient manner.”
The bank particularly highlighted data accuracy and timeliness as issues, along with confusion over technical standards.
NAB stated the multitude of regulatory bodies and agencies involved in the CDR oversight “has been the source of some confusion and delay in the past, when trying to clarify aspects of the technical standards”.
“Guidelines from one party may imply one meaning, while the CDR Support Portal hosted on ZenDesk, may give a conflicting or slightly different interpretation.
“Delays in confirming the correct information can impede customer innovation and product development, and the implementation of new CDR use cases.”
“It would be helpful to data holders and recipients to have a single, accurate source of truth for technical standards, that they can turn to.”
Updates to CDR rules “caused some challenges for NAB in the past,” including go-live dates landing during the new financial year.
It argued the lack of regularly occurring updates to the CDR rules “limits the ability for data holders and recipients to efficiently plan and prioritise their CDR investments and resourcing”.
It called for timed changes, which would enable NAB to plan ahead and “provide appropriate feedback to these proposed revisions”.
Consultation on rule changes can be rushed, NAB said, meaning potential feedback isn’t given.
“While NAB understands the need for these consultations to be targeted and efficient, it would be beneficial if there was greater opportunity to raise related or supplementary issues during these processes, in order to avoid duplication and inhibit product development and functionality,” it said.
It also warned that direct-to-consumer data sharing offers opportunities for frauds and scam.
“The right authentication and authorisation standards will also need to be incorporated, to ensure a scenario where what could be considered screen-sharing by proxy, does not occur.
“It may also be beneficial to delay the implementation of direct-to-consumer sharing until the uptake of current CDR use cases and functionalities has grown, and consumers are more familiar with these capabilities and the benefits that they can provide.”
More CDR users would also provide data holders and recipients “with greater confidence” around the commerciality of bringing direct-to-consumer sharing use cases to market.
NAB added it doesn’t see any need for statutory changes within CDR for digital identity, “we consider that it is important to clarify and understand the continued intersection between CDR and digital identity.”
“Each system needs to maintain their own independence, as not all digital identity use cases will involve data sharing or have a link into CDR use cases.
“But CDR will become a very important user of an interoperable digital identity ecosystem, driving strong consumer choice and a more streamlined approach to customer verification and authentication requirements under CDR,” the bank claimed.
NAB also wants digital platforms considered for expansion of the CDR.
“Given the vast presence of these platforms and the considerable volume of consumer data that they now hold, we see significant potential in the market for innovative customer use cases, and opportunities to ensure that consumers are fully empowered with control of their data.”
