Data Standards Advisory Committee, Meeting Minutes
Date: Wednesday 13 March 2019
Location: Data61, Level 5, 13 Garden Street, Eveleigh
Time: 14:00 to 16:00
Meeting: Committee Meeting No: 8
- Andrew Stevens, DSB Chair
- Kate Crous, CBA
- Emma Gray, ANZ
- Mark Perry, Ping Identity
- Lisa Schutz, Verifier (via WebEx)
- Ross Sharrott, Monetree
- John Stanton, Comms Alliance (via WebEx)
- Stuart Stoyan, MoneyPlace
- Jamie Twiss, Westpac (via WebEx)
- Mal Webster, Endeavour Bank
- Warren Bradey, Data61
- James Bligh, Data61
- John Brøndum, Data61
- Stuart Low, Data61
- Terri McLachlan, Data61
- Michael Palmyre, Data61
- Mark Staples, Data61
- Stephen Bordignon, ACCC
- Bruce Cooper, ACCC
- Anjelica Paul, OAIC (via WebEx)
- Daniel McAuliffe, Treasury (via WebEx)
- Lauren Solomon, CPRC
- Luis Uguina Carrion, Macquarie Bank
- Patrick Wright, NAB
- Viveka Weiley, Choice
- Andy White, AusPayNet
The Chair of the Data Standards Body (DSB) opened the meeting and thanked all committee members and observers for attending Meeting No 8.
The Chair noted that at this meeting there will be a focus on updates from Treasury on the timing and the legislation; updates from ACCC on the appointment of the contractor and status of the registry build; and an update on the findings and recommendations following the CX review.
The Chair advised that both he and Warren Bradey were invited by the Senate Economics Committee to attend a public hearing into the inquiry into the Treasury Laws Amendment (Consumer Data Right) Bill 2019 on Wednesday 6 March 2019. The Chair noted that Senator Hume thought that the DSB consultation process we have used was very transparent and probably the most all-encompassing that she has seen. The Chair noted that it was interesting to get an external review.
The Chair noted that Lauren Solomon (CPRC), Luis Uguina Carrion (Macquarie), Viveka Weiley (Choice), Andy White (Australian Payment Networks) & Patrick Wright (NAB) were apologies for this meeting.
The Chair thanked the Committee Members for their comments and feedback on the Minutes from the 6 February 2019 Advisory Committee Meeting. The Minutes were taken as read and formally accepted.
The Chair noted that the Action Items were either completed or would be covered off in discussion during this meeting.
Technical Working Group Update
A summary of the progress from the last committee meeting on the Technical Working Groups was provided by John Brøndum.
It was noted that the API Standards Team is close to finalising API end points and payloads and locking down version 1. It was noted that the non-functional requirements (NFR) consultation period is now complete and the final responses are being reviewed internally prior to the final Decision being published on GitHub.
It was noted that the Engineering Team ran its initial Engineering Workshops in Sydney and Melbourne on the 6th and 7th March 2019 which will be followed up with the distribution of materials and a questionnaire to the participants to ensure we are focussed on high priority areas for the eco-system.
It was noted that the Consumer Experience Team have completed their research and published the Phase 1 CX report. The research findings and recommendations are currently open for consultation and feedback until 15 March 2019.
A further discussion was held on NFR’s, and the API Lead confirmed that all feedback obtained from the community has been posted on GitHub. It was noted that the recommended position on the NFR’s will benefit from being tested against “real world conditions” and the proposed pilot trials will help inform all parties of any further refinements that should be addressed prior to the regime being formally launched in February 2020.
A discussion was held on whether the meeting would include consideration of the current position adopted in the areas of joint account and authentication processes. The Chair advised that this would be deferred until after the ACCC published the next version of the rules.
A discussion was held on Product Reference Data. The API Lead advised that this has been the main priority over the last couple of weeks. He noted the team has met with ABA and members and aggregated all the feedback, including around feature types, lending and how to handle tiered interest rates. It was noted that after discussion with the ABA this would form the basis for now finalising a version 1 to enable the banks to build and test around this set of data prior to implementation. The next phase is for the Chair to review the recommendations next week and for the final version to be published as normal through GitHub.
A summary of the progress since the last committee meeting on each Working Group was provided in the Committee Papers and was taken as read.
Michael Palmyre the CX Working Group Lead from Data61 CDS team provided the following update on the Phase 1 CX Report (February 2019).
The Consumer Experience Team has completed the research undertaken and today will provide a summary of the Phase 1 research approach, key findings and recommendations of the work followed by the proposed next steps.
It was noted the core of the research undertaken was qualitative detailed interviews with consumers recruited by CHOICE. As part of the selection process feedback was provided by the eco-system on the types of consumers that should be included.
Overall the research covered a total of 80 participants, of which half were consumers and half were SME’s (sole traders). The research aimed for gender parity, regular technology users, late and early adopters, demographic diversity, consumers with accessibility needs and those located in remote and rural locations.
It was noted there were three components to the research, totalling three rounds of qualitative research and one survey. The first component involved a ' Card Sort' exercise with 10 participants. This tested the language and data clusters with a generative card sorting exercise. This involved an activity where participants organised and named information in ways that made sense to them.
The second component was the “Survey” which was accompanied by open-ended questions. The survey explored participant comprehension of language used to describe data and the level of comfort with sharing certain types of data. This survey had about 50 participants.
The third component involved two rounds of qualitative research and prototype testing to explore consumer expectations, needs, and behaviours in relation to the sharing of financial data. This component engaged 20 participants and ran from January 2019 to the first week in February 2019.
A discussion was held on how we found the groups to participate in the research. It was noted that CHOICE located participants and confirmed that people generally were keen to be involved in the research and the concept of data sharing and they provided informed feedback. It was also noted that the qualitative research included only a limited number of young people as we had lower access to those groups and it is recognised there is a need to engage young early adopters in subsequent research.
In regards to testing the consent flows it was noted these flows tested well overall, although the results showed there are some areas that require refinement and improvement. It was noted the outcomes provide a reasonable level of confidence that consumers will understand how to navigate this process. It was noted the largest barrier to consent related to concerns around how data would be used.
The research showed that the extent of data sharing will be context dependent. One example from the research participants was that they wouldn’t share their personal banking data with companies outside their bank, but when they were presented with a use case relevant to them, they were ok to share their data. This was interpreted to mean that for data recipients, the value proposition will need to be strong to achieve uptake of a service.
It was also noted that as part of the survey held, 39% of respondents indicated they wouldn’t share their personal banking data with companies outside the bank, however, 55% of those 39% of participants suggest they would be willing if the benefit or purpose was clear.
The research showed prior knowledge of the CDR and the data recipient is very important. This indicates it will be important for a broad education campaign be undertaken to inform consumers. The results were not as clear on whether education will need to be persistent or will be retained if it is provided once at the commencement of the regime.
In regards to the preliminary recommendations in defining and standardising the ‘unambiguous disclosure’ Rule (7.13d) the findings indicated there should be a clear understanding provided of what constitutes ‘unambiguous disclosure’ of data use.
It was noted that the research suggests that data recipients should clearly state why each data cluster is being requested, and how far back in time data will be accessed to improve understanding. It was noted the research suggests that data recipients should clearly state the agreement term, and whether they will keep the data following the access period. It was noted that there was an assumption by most participants that the data would be used for marketing until explicitly advised otherwise.
A discussion was held on the authentication model proposed by the standards and the rules (re-direct through known channels). Whilst it was noted that this decision had been part of the open GitHub publication and discussion process previously the Chair agreed that the comments provided in that Decision Process would be reviewed again to consider whether any changes should be made to that approach.
The research overwhelmingly showed that most participants would use a non-digital means of revocation first, especially phone, in-person, or by email. It was noted that for this reason no single channel for revocation should be mandated by the standards.
At present, digital dashboards are proposed as the only means of revocation. Further research proposed will evaluate whether data holders and data recipients should provide non-digital and email channels as initial contact points that can then guide consumers to complete the revocation process themselves.
It was noted that the preliminary recommendations of the CX report are subject to further research and that ACCC and Data61 are scoping out a next phase to cover issues highlighted as preliminary recommendations.
It was noted that a broad next phase scope of CX work has been developed and feedback is being sought from the CDR community for comments on key issues they believe should be included as a result of the Phase 1 findings.
Daniel McAuliffe from Treasury provided an update on the Consumer Data Right Legislation and the Senate Economic Hearing.
Treasury advised that the Consumer Data Right Legislation was introduced to Parliament on the 13th February 2019 and also had its second hearing at the same time. In order for the Bill to be passed before the election it would need to be debated and passed on budget day by the Lower House and on the subsequent day by the Upper House.
It was noted that the Senate Economics Legislation Committee public hearing for the inquiry into the Treasury Laws Amendment (Consumer Data Right) Bill 2019 was held on the 5 & 6 March 2019.
Daniel outlined some of the issues that were raised by groups appearing before the Senate Committee hearing. One issue was the privacy impact assessment, risk assessment and the consultation process which was conducted by Treasury and whether an independent party should have been engaged. Another issue raised was around reciprocity being too broad and thirdly there were strong views for a broader privacy reform. There was also some concerns noted about what happens with redundant data and whether it is deleted or de-identified. Other issues were raised. It was noted that for a number of issues raised there was a lot of views expressed both positive and negative.
Committee members discussed whether the CDR regime would be held up significantly or changed if there is a change to a Labour Government in the upcoming election.
It was noted that if the bill is not passed prior to the upcoming election, it will need to be re-introduced and considered again by Parliament and this would more likely happen in the spring sitting at the end of the year.
Bruce Cooper from the ACCC provided an update on the directory status, the draft rules, the finance sector survey and the energy sector consultation.
ACCC advised that they are continuing to work with the current timetable and moving forward with the build of the IT component. They will be publishing the rules at the end of March 2019 with the view of testing between July 2019 and February 2020.
ACCC confirmed that they have engaged Oakton as their IT build consultants for the address book/directory. The aim is to have the 1st version up and running in May 2019 with testing in June 2019 and a first version operating in July 2019 to facilitate the pilot testing development. It was noted Oakton have been on board for approximately three weeks and have already commenced design workshops with Data61.
A discussion was held on the specifications and when ACCC will publish these elements of the design as it is noted dataholders will need to develop their platform based on a hard set of designs. It was noted ACCC is keen to collaborate on the specifications and will commence a broader consultation in the near future.
A discussion was held on whether ACCC will continue in light of the delays with the legislation being passed. ACCC advised that the timetable has been set and they are proceeding accordingly. It was noted that the rules to be released by the end of March 2019 will be issued as a consultation draft with industry stakeholders. ACCC advised that it is their intention to work as openly and transparently as possible.
A discussion was held on the status of the accreditation process, IT security guidance, insurance guidance and the explanatory material which will accompany the rules. ACCC advised that these are all progressing to date. Although it was noted they will be issued subsequent to the issue of the draft rules.
A query was raised about what happens if there is a change of government and the new minister has a different view on implementing CDR. ACCC advised that if there is a change of government, Treasury and ACCC would seek to meet with the Treasurer’s office to obtain clarity and input on an implementation timetable if it was to be different to the current schedule.
ACCC advised that the CDR implementation survey (banking) was published Friday 8 March 2019. This survey is to better understand the number of stakeholders interested in being accredited under the CDR regime. Approximately 20 people had responded to the survey to date.
ACCC advised that they will be running an energy sector consultation process on 18 March 2019. This is to consult with the community on the best way to access the data in the energy sector.
On behalf of Andy White, Australian Payment Network, the Chair asked the Advisory Committee to consider whether the Australian and New Zealand Productivity Commission attend the meetings. This is reference to the table 4.1 of the joint research report on “Including New Zealand representatives in the open banking working groups in Australia”.
A discussion was held on whether it was appropriate if they join as a committee member or observer and it was agreed that it may be useful as an observer which could encourage early adoption in NZ. It was agreed that further information is required on who they are suggesting and what they are proposing and bring back to the April 2019 meeting.
ACTION: Obtain further details on the proposal and include as an agenda item for the April 2019 meeting.
The Chair advised that ACCC and Data61 are scheduling some bank liaison meetings with the four major banks. Sarah Court from the ACCC will also be attending. The objective of the meetings is to go through the timetable, discuss how we go forward without legislation and how to best engage with other banks who might be interested in becoming a data holder earlier.
The Chair thanked Michael Palmyre for his presentation on the UX recommendations and findings.
The Chair also advised the committee that Ellen Broad gave birth to Jean Molly Maras on 4 March 2019.
The Chair advised that the next meeting will be held on Wednesday 10 April 2019 from 2pm to 4pm at the Data61 offices in Eveleigh.
The Chair asked all committee members to consider the proposed Advisory Committee dates that were included in the March 2019 papers and get back to Terri McLachlan with any issues.
ACTION: Committee members to consider and advise any suggested changes to the proposed committee dates for remainder of 2019 year.
Closing and Next Steps
The Chair thanked the Committee Members and Observers for attending the meeting.
Meeting closed at 16:00