When did it start to go so wrong?
Jamie K Leach (MAppFin - GAICD)
Open Data | Digital Identity | Data Champion | Board Chair - [email protected]
In the past week, I was asked by three different connections on three different continents;
"Is the Consumer Data Right dead?"
"If it is not dead, is it dying?"
"When did it start to go so wrong?"
"Will you ever realise its promised true-potential?"
"Can it be fixed?"
With each question and set of inquisitive eyes boring their way into my soul, I felt like I had been punched in the gut. My initial reaction was to deny that any of these questions had any weight.
"No, the CDR is not dead..."
"It hasn't quite gone to plan..."
"There are a number of reasons why we have gotten to where we have gotten..."
But as I opened my mouth to muster a reassuring smile and promote what should be the World's leading example of a consumer-centric consented data-sharing ecosystem, I wondered where we had landed in the evolution of the CDR. The CDR is paving the way for a truly open-data-driven economy, but even I was questioning where and when it had stalled.
And stalled it has. The silence is deafening.
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Despite Australia's largest banks commencing their data sharing in early 2020, with the BIG-4 getting the ball rolling, the remaining brands joined the party in 2021. From 2019 - 2021, a flurry of iterative rules and regulations were published, and the last time the Competition and Consumer Act was amended was in November 2022. The Energy Sector was designated, and the largest brands were mandated to share a small subset of data in November 2022.
2022 also saw the commissioning of the first Statutory Review into the initial roll-out of the CDR and the Future Direction for the regime. The Australian Government released its statement in response to the review findings in June 2023. However, despite removing telecommunications, action initiation, payment Initiation, and superannuation from the list and announcing non-bank lending, the list has remained suspiciously empty from June 2023 to now.
Even the cdr.gov.au website has not had its timeline updated.
I appreciate that I am sitting in a privileged position, both personally and professionally. I am privy to Industry conversations, with Data Recipients and Data Holders, and conversations with many people within the Government and Regulator on a daily basis.
And let me share that both sides of the table are battle-weary.
If someone had told me, way back in 2018, that this country would mandate a revolutionary data-sharing regime, a regime that had the supreme promise of massive benefit to citizens, businesses, and the nation, in privacy, convenience, economic returns or enhanced products and services, only to let that promise decay before our very eyes, I would have been horrified.
I speak to participants on a weekly basis who are ready to give up on their dreams. Their investments and commercially viable use cases eroding rapidly. I speak to would-be participants who would love to be included but literally can't with the current state of the regime. Businesses are redeploying whole teams of people who were building/servicing the CDR solutions. Multinationals are choosing not to enter this country now because it is all too hard. Worse still, competitors and solutions that are not interoperable with the legislation, regulation or rules are sensing an opportunity to enter this territory. I am all for competition, but with each new entrant that is not CDR-related, it gets harder to sell the CDR as the true way forward.
The saddest part is that we can rectify all of the sticking points. We can reduce the costs of participation, simplify the process, reduce the burden of compliance, raise the privacy and security stakes, and, above all else, whack a gigantic set of defibrillators on this patient and shock life back into the regime.
So, with reflection, the CDR isn't dead. It has stalled. The promise has yet to be realised. But there is nothing that can't be remedied or repaired. And above all else, with the eyes of the World watching our next move, there is a willing group of privileged folks who desperately want to assist in this resuscitation to benefit consumers, industry, and the nation's economy. You already know the number. We will answer that call to action!
CEO - Founder | World Data Exchange & ID Exchange * OWI Top 100 Digital ID Influencer * Patient Centric data sharing platform * Data Intermediary * Disruptor * Multi Award Winning Technologist
5 个月IMO...it was reduced to a banker's data right, not a true consumer data right model in the early days as many failed to understand the limited path that was taken whilst industry posturing overtook the impacts of understanding and managing policy, rules and regulation with data use restrictions agreed via a sectoral based approach. Then add undue layers of standards compexity which the DSB should not have allowed. #Shortsighted greed and vested intetests = cluster-fail.
Partner @ RSM Australia | Cyber Security, SOC 2, CPS 234, CDR | CREST penetration testing
5 个月It feels that with each set of Rule changes, tweaks have been made to try and fix some of the specific issues but these changes have just made things even more complicated and not addressed any of the root causes. I talk to potential participants on a weekly basis where the work arounds required put things into the too hard bucket - yes more CDR use cases are going live but the ratio of new screen scraping use cases vs CDR use cases is massively one sided.
Product Strategy; Open Data and Digital Identity
5 个月If feels like the CDR is limping along with a broken leg and whilst it can get by with crutches and eventually arrive at the shortest destination it needs a team of experts and a surgeon to really come in and fix the broken leg! It's worrying that the latest Federal Budget had no funding for CDR included and we are still in the dark on any quantifiable outcomes of success. There is so much opportunity but agree with Mike, it should be about how the CDR enables outcomes, not about finding (very expensive) ways around the rules to arrive at the eventual destination. It's all so fixable to your point Jamie. But who is listening?
CPA, CISA, CISM, MBA
5 个月Well - one thought would be to separate governance (accreditation, disputes, liability management, monitoring, etc) from the data standards. Let the industry collaboratively define and maintain the data standards so that it can innovate as fast as the customer's needs dictate. This strikes the right balance between the end user (and their needs) driving things while preserving rules based governance. This model works well elsewhere.
CTO at DBG Health
5 个月Great article Jamie. I agree with Jill that, from a pure ecosystem perspective, the CDR continues to grow. The issue is leadership. There is no certainty about action initiation, non-bank lenders, needed fixes to the existing rules, etc. These are all problems at the political level unfortunately.