Review a Consumer Data Right participation agreement and API terms

Key facts

Human involvement
YellowClose supervision
How AI is used
Line up data-holder, accredited-recipient and API obligations in the agreement against the CDR Rules and OAIC CDR Privacy Safeguards the lawyer has named, marking gaps.
What the lawyer must review
  • Check the CDR Rules and Data Standards (e.g. FAPI 1.0 Advanced) on consumerdatastandards.au
  • Check the CDR Register
  • Do not treat outsourcing as shifting the data holder's duties (Privacy Safeguard 11)
  • Note the OAIC's Regional Australia Bank determination (May 2025)
  • Check Treasury's timeline for non-bank lenders
  • Confirm Privacy Safeguard 12 deletion duties
Written for / version
Commonwealth versionCth

Rules that apply

The document starts from the task name. Change it if this piece of work is different.

Who does what

Who does what
RoleWhat they do
AssistanceConsider narrowly defined preparation support after confirming the tool’s capability and permitted scope.
LawyerSet the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output.

Checklist

  1. Review operative clauses in the complete document, including definitions, cross-references, schedules and inconsistencies with the instructions.
  2. Confirm that the actual tool, feature and processing terms permit use of this information, including access, retention, training and disclosure conditions.
  3. Obtain and inspect the relevant current official register or search result. Confirm identities, interests and the date and scope of the search.
  4. Verify dates, people and sequence against contemporaneous records. Preserve uncertainty and identify gaps or conflicting accounts.
  5. Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
  6. Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.

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