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The Australian Competition and Consumer Commission (ACCC) and the Office of the Australian Information Commissioner (OAIC) have revealed that they are treating data quality in the open banking ecosystem as “a priority area for compliance and enforcement activities”.
The move comes after the competition watchdog consulted stakeholders on the “prevalence of, and harm caused by, data quality issues” in the Consumer Data Right (CDR) ecosystem after raising over 280 separate issues relating to data quality with data holders.
In total, 15 stakeholders from across the CDR engaged in the consultation, with the ACCC receiving 12 written submissions and holding 13 bilateral meetings.
Releasing the findings from its consultation, the competition watchdog outlined that poor data quality was limiting wider adoption of the system and that there was general consensus that regulators should be prepared to take a stronger regulatory approach to improve data quality.
Stakeholders reportedly suggested that increased regulatory actions “would send a clear message about the importance of complying with data quality obligations”.
As such, it said that the ACCC and OAIC would treat data quality as a priority area for compliance and enforcement activities.
Specifically, the ACCC said it would increase its enforcement activities to address data quality non-compliance in relation to a number of specific issues including:
- Incorrect interest rates in product reference data on home loans, savings accounts, and credit card products
- Information shared in free text fields, rather than relevant structured fields
- Missing or incomplete data
- Instances where the data provided is not commensurate with what a consumer can otherwise see in their online or mobile banking channels
- Instances where there are slow or insufficient responses to data quality issues
The ACCC outlined it would also work with Treasury, the 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.
It would also consider options to improve participant experience, for example, publishing information about data holder implementations so that data recipients can develop use cases accordingly.
The third action that the ACCC said it would undertake was improving the Service Management Portal through which stakeholders can raise data quality issues (in a bid to improve response times on tickets and review trends to ensure incidents are appropriately tracked) and considering publishing known issues with product reference data relating to individual data holders to promote compliance.
The body said it would also work closely with participants and other CDR agencies to “explore opportunities for a dedicated channel through which users of product reference data can raise issues directly with data holders.”
The report read: “CDR participants must comply with their obligations. In particular, the ACCC expects data holders to regularly review the efficacy of their CDR solutions and address any outstanding data quality incidents as a priority.
“In the short term, the ACCC’s CDR compliance and enforcement efforts will be focussed on regulatory action for data quality issues…
“There is no single solution for improving data quality in the CDR.
“Instead, the necessary response will need to encompass a combination of: clear regulatory obligations; effective guidance; constructive stakeholder engagement; strong regulatory action; and an improved culture of compliance among participants.”
Key findings from the consultation
Other key findings from the consultation included:
Data quality generally sufficient
The quality of consumer data is generally sufficient to support the delivery of CDR products and services, although reliability was a factor.
Some data holders were reportedly failing to disclose around half of all consumer transactions that should be covered in the CDR data, the consultation revealed.
Shortcomings in product reference data
According to CDR users, the majority of data holders have at least some data quality issues present in their product data, with incorrect interest rates a particularly prevalent and high-impact issue. For example, one individual cited in the report outlined that they had signed up to a savings account based on a rate disclosed through CDR, only to find it was incorrect.
Responsiveness in fixing issues
Data recipients and users of product reference data told the ACCC that there were concerns over the responsiveness of data holders when data quality issues had been raised with them.
For example, a respondent gave examples of their customers contacting data holders only to be told by frontline staff that data sharing is not possible.
Clarifying expectations and terminology
Lastly, the ACCC outlined that the engagement found scope to clarify the nature of data quality obligations to ensure a better understanding of expectations around appropriate data quality.
For example, the ACCC consultation revealed that there was confusion around what the ‘optional’ fields meant and that the absence of this important information was “having a high impact on the delivery of their CDR goods and services”.
The watchdog clarified that, in the standards, ‘optional’ refers to information that must be disclosed if it is held and relevant to a given consumer data request. For example, lending rate fields are ‘optional’ because some products (such as a basic transaction account) may not have any lending rate.
“The categorisation of data as ‘optional’ in the standards indicates that a given field is not required in order to comply with the technical schema outlined in the standards,” the ACCC clarified.
“It is not an indication that data holders can elect not to disclose particular information if they have it … Data holders may not be providing this information even though they hold it and it is relevant to a particular data request.
[Related: CDR data quality issues targeted in new consultation]
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