Optionality of critical fields is facilitating data quality issues across Data Holder implementations

[ShaneDoolanAdatree]

Description

The below is taken from the Payload Conventions section of the Standards: https://consumerdatastandardsaustralia.github.io/standards/#payload-conventions

Note that optional fields are not considered optionally implementable by a Data Holder. For instance, if a Data Holder holds data in digital form for a Customer that is represented in a payload then it is expected that this data will be shared when authorised by the Customer. For payloads unrelated to Customers, such as product reference data, there is more discretion for the Data Holder but other drivers, such as complementary regulation or the requirement to align to other channels, should be taken into consideration.

Unfortunately for ADRs and consumers, despite this explicit statement, some major Data Holders are taking optional fields as literally optional. The worst and most worrying example of this is within the BankingAccountDetail payload where for loan account types they are not including obviously required data such as lendingRate and the lendingRates array of BankingProductLendingRate type.

This behaviour is not only in breach of the above statement from the Standards, but we believe it is also a breach of Schedule 3 Rule 1.4 of the Rules. But, making the fields optional in the Standards, despite the above Standards statement on optionality, gives Data Holders and their implementing teams some room to debate the issue and/or make mistakes.

Area Affected

https://consumerdatastandardsaustralia.github.io/standards/#tocSbankingaccountdetailv2

Change Proposed

As an urgent change I would request the below fields that are part of BankingAccountDetailV2 be made conditional with a statement to the effect of "if a loan has a rate then include the rate/rates" (blatantly obvious as that may seem but... here we are).

• lendingRate
• lendingRates

As a more forward looking change I would request that we review the use of the word optional within the Standards entirely as the explicit statement about optionality by the Standards seems to be easy for Data Holders to ignore and hard for ADRs to enforce.