ACCC & DSB | CDR Implementation Call Agenda & Meeting Notes | 15th of February 2024 - ConsumerDataStandardsAustralia/standards GitHub Wiki

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Agenda & Meeting Notes

When: Weekly every Thursday at 3pm-4:30pm AEDT
Location: Microsoft Teams
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Agenda

  1. Introductions
  2. House Keeping
  3. Updates
  4. CDR Stream updates
  5. Presentation
  6. Q&A
  7. Any other business

Introductions

1ImpCallHeaders

  • 5 min will be al lowed for participants to join the call.

Acknowledgement of Country

We acknowledge the Traditional Custodians of the various lands on which we work today and the Aboriginal and Torres Strait Islander people participating in this call.

We pay our respects to Elders past, present and emerging, and recognise and celebrate the diversity of Aboriginal peoples and their ongoing cultures and connections to the lands and waters of Australia.

House Keeping

2ImpCallHeaders

Recording

The Consumer Data Right Implementation Calls are recorded for note taking purposes. All recordings are kept securely, as are the transcripts which may be made from them. No identifying material shall be provided without the participant's consent. Participants may [email protected] should they have any further questions or wish to have any material redacted from the record.

Community Guidelines

By participating in the Consumer Data Right Implementation Call you agree to the Community Guidelines. These guidelines intend to provide a safe and constructive space for members to discuss implementation topics with other participants and members of the ACCC and Data Standards Body.

Updates

3ImpCallHeaders ⭐ indicates change from last week.

Type Topic Update
Standards Version 1.29.0 Published: 21st December 2023
Change log
Maintenance Maintenance Iteration 18 commenced on the 7th February 2024 Agenda
Please reach out to [email protected] for an invitation
DSB Newsletter To subscribe to DSB Newsletter Link here
DSB Newsletter ⭐ 9th of February 2024 View in browser here
Consultation Decision Proposal 229 - CDR Participant Representation Placeholder: no close date
Link to consultation
Consultation Noting Paper 279 - Accessibility Improvement Plan No Close Date
Link to consultation
Consultation Noting Paper 323 - NFR Workshops Link to consultation
Consultation Noting Paper 330 - UNSW Reports Link to consultation
Consultation Decision Proposal 340 - Maintenance Iteration 18 Link to consultation
Consultation Noting Paper 342 - Information Security Working Group Link to consultation
Survey If you are a CDR stakeholder, we want to hear about your experience finding and using CDR guidance. The ACCC has released a survey for businesses and individuals who are holder or receivers of CDR data, or who provide services to these parties. This includes, for example, data holders, accredited persons, CDR representatives and third-party service providers. Your response will help us assess the effectiveness of CDR guidance and identify potential areas for improvement. The survey is available on the ACCC website and will remain open until 25 March 2024.
Engineering Update to Product Comparator Demo
Improved CORS error logging. Where it checks that the x-v header of the response can be read by a cross-origin web client.
Product Comparator Demo

CDR Stream Updates

4ImpCallHeaders Provides a weekly update on the activities of each CDR stream and their work.

Organisation Stream Member
ACCC Register and Accreditation Application Platform, Conformance Test Suite & Participant Tooling Christian
DSB Consumer Experience Michael
AEMO Status and Outage APIs John

Presentation

5ImpCallHeaders None this week.

Q&A

6ImpCallHeaders Questions on Notice

Questions will be received by the community via Microsoft Teams chat before the questions are opened to the floor. Participants can submit questions outside of the CDR Implementation Call to the CDR Support Portal.

In regards to topics for questions, we ask the participants on the call to consider the Community Guidelines when posing questions to the subject matter experts.

Answer provided

Ticket # Question Answer
2224 Just to clarify further as this guidance article doesn't explicitly outline it, for calls passed through to the secondary data holder, is the calculation method for the response time EXCLUDING the secondary data holder response times?
For instance if a call comes into Get Usage, requires 2 secondary data holder calls each taking 1 second and the total time end to end for the call is 2.5 seconds is the calculated response times as follows:
AverageResponseMetricsV2 .primary: 2.5 seconds total - (2 x 1 second per SDH call) = 0.5 seconds?
AverageResponseMetricsV2 .secondary: 2 x 1 second = 1 second ?
It’s not clear what you mean by excluding secondary data holder (SDH) times. If you mean that the primary data holder (PDH) average response times should exclude SDH times, then that is correct.
An example formula would be like below:
Average Response Time = response time taken by DH (if PDH, excludes SDH and vice versa) / number of API calls
Using that in your example we get the following:
- AverageResponseMetricsV2.secondary.primary = 0.5 / 1 = 0.5
- AverageResponseMetricsV2.secondary.secondary = 2 / 2 = 1
2246 Scenario: Consider ADR2 has received collection and use consent request from ADR1. Now here ADR2 decides to obtain a disclosure consent from the consumer in order to disclose the required CDR data to ADR1. As per the rule 4.11(ba) (rule - in the case of a disclosure consent―allow the CDR consumer to select the person to whom the CDR data may be disclosed), if our ADR2 provides the option to select the ADR to disclose CDR data and user here selects ADR3 then it will not fulfil the collection and use consent i.e. ADR2 will not be able to share data to ADR1.
Could you describe/guide, what is the purpose of this rule in this scenario?
As you may be aware, the purpose of Division 4.3, as outlined in rule 4.9, is to ensure CDR consents are voluntary, express, informed, specific as to purpose, time limited, and easily withdrawn. Rule 4.11(1)(ba) is one of many provisions in Division 4.3 that is designed to facilitate these purposes by requiring the CDR consumer to actively select the person to whom they want to disclose data.
2247 Can an ADR give AP disclosure consent without collection and use consent? Rule 4.7B lists the requirements that must be satisfied before an ADR may ask an eligible CDR consumer for an AP disclosure consent. One of the requirements is that an ADR must have received, or reasonably anticipates receiving, a relevant consumer data request under rule 4.7A before it can request a CDR consumer to give an AP disclosure consent. Rule 4.7A provides that an accredited person can only request (on behalf of a CDR consumer) that the ADR disclose data in relation to which the consumer has given a valid request under rule 4.3 or 4.3A and can only disclose “some or all of the CDR data that is the subject of the relevant collection consent and use consent”. The ACCC’s view is that an ADR cannot request an AP disclosure consent from a CDR consumer in the absence of a relevant collection and use consent because in these circumstances there would be no reasonable expectation of receiving a request under rule 4.7A.
Furthermore, we note that rule 7.5(1)(i) states that disclosing CDR data to an accredited person is only a permitted use or disclosure for an ADR that has collected CDR data under a consumer data request, if the CDR consumer has given:
the accredited person a relevant collection and use consent; and
the ADR an AP disclosure consent to disclose the CDR data to the accredited person.
Hence, the disclosure of data in response to an AP disclosure consent is not a permitted use or disclosure of CDR data if the CDR consumer has not given a relevant collection and use consent.
2265 Last year Energy Data Holder performance metrics were published alongside Banking (see https://www.cdr.gov.au/performance). This triggered a number of internal discussions as to interpretation of GetMetrics and how they align to Non-functional Requirements (NFRs).
See attached JPEG for screenshot and context.
Chief call out here is that the hover over from the published metrics which shows an applicable Threshold of 1 second for 'Secondary Response - Primary DH'.
Question a) Can you please confirm this threshold is referencing the NFR's in the CDS, specifically:
Secondary Request
1000ms (for data holders)
1500ms (for secondary data holders)
If the above is true, it appears we have a misalignment of interpretation in the metrics as the published figures appear to assume that the reported response times in GetMetrics captures the time for the Primary DH only (1000ms), and not the entire round trip for the response ie. Primary DH + Secondary DH and back again, or 2500ms.
Question b) Can you please confirm that the expectation for Get Metrics and therefore the published figures in CDR Performance for 'Secondary Response - Primary DH', expects only to show the time taken for a Primary Data Holder to pass the request to the Secondary Data Holder; OR Is the expectation that GetMetrics data reports the entire round trip for a given response ie. Primary DH to Secondary DH, and Secondary back to Primary?
If the latter is the case the hover over on the Performance website seems to be incorrect given the threshold would be 2.5 secs, not 1 sec. If the former is correct then there is some ambiguity in the GetMetrics requirements as this is not declared specifically. I believe we are currently reporting the aggregate times, ie the Primary and Secondary DH response times together.
Question a) Can you please confirm this threshold is referencing the NFR's in the CDS, specifically:
Secondary Request
1000ms (for data holders)
1500ms (for secondary data holders)

Yes that is correct. The performance requirements in the NFR are noted for each data holder (Primary and Secondary) individually.
Question b) Can you please confirm that the expectation for Get Metrics and therefore the published figures in CDR Performance for 'Secondary Response - Primary DH', expects only to show the time taken for a Primary Data Holder to pass the request to the Secondary Data Holder; OR Is the expectation that GetMetrics data reports the entire round trip for a given response ie. Primary DH to Secondary DH, and Secondary back to Primary?
GetMetrics is aligned to the NFRs and reports the Primary Data Holder (PDH) and Secondary Data Holder (SDH) performance requirements individually. The primary data holder (PDH) average response times should exclude SDH times and vice versa.
- An example formula on how it would be calculated is below:
Average Response Time = response time taken by DH (if PDH, excludes SDH and vice versa) / number of API calls received by the DH.
Hope this clarifies. We will update our guidance article on CDR Metrics to include the above clarification.

Any Other Business

7ImpCallHeaders Attendees are invited to raise topics related to the Consumer Data Right that would benefit from the DSB and ACCCs' consideration.

Useful Links

View a number of informative and useful links in the Consumer Data Standards Guide on Information Links.

Check out our guides, browse through our FAQs, and post your own questions for Support. The official Consumer Data Standards website This repository contains the binding API Standards and Information Security profile created in response to the Consumer Data Right legislation and the subsequent regulatory rules. A demonstration of Product Reference data from the Banking Sector.
Consumber Data Standards on GitHub Data Standards Body video channel on YouTube Helping organisations provide consumers with intuitive, informed, and trustworthy data sharing experiences. A Postman collection with a set of unit tests. It can be used as a development testing tool for Data Holders developing a DSB compliant API.
Follow Data Standards Body on LinkedIn for updates and announcements Digital Resources Repository on DSB's GitHub website The glossary of CDR CX terminology Data Holder server reference implementation and associated tools.
  A repository of DSB Newsletters/Blog posts since 2019 This repository is the staging repository for the Consumer Data Standards. Java Artefacts Data Holder server reference implementation
  This glossary lists terms and their definitions in the context of the Consumer Data Right and Consumer Data Standards. This repository is used to contain discussions and contributions from the community of participants and other interested parties in the Australian Consumer Data Right regime. Java Artefacts Data Holder server reference implementation
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