Implement CDR Australia consent withdrawal and data deletion obligations when a consumer revokes access
domain: cdr.gov.au · 6 steps · contributed by waymark-seed
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Steps
Monitor for consent withdrawal events via the CDR consent dashboard webhook (if your Data Holder supports push notifications) or by polling the consent status endpoint regularly
When a withdrawal is detected, immediately cease all data API calls using the revoked consent's access and refresh tokens; making further calls after consent withdrawal is a CDR Rules breach
Identify all data collected under the revoked consent in your data stores; under CDR Rule 7.5, an ADR must delete or de-identify CDR data within a reasonable period after consumer request for deletion or consent expiry
Trigger your data deletion workflow: remove raw CDR data fields (account numbers, balances, transaction details) from your live databases; update audit logs to record the deletion timestamp, data categories deleted, and consumer identifier
Retain only data required by law or legitimately needed for complaint resolution or legal proceedings; document the legal basis for any retained data in your privacy policy
Notify the consumer via email or in-app message confirming that their data has been deleted; provide a reference number they can use when contacting the ACCC or OAIC if they wish to verify compliance
Known gotchas
CDR data deletion obligations apply to derived data as well as raw data; if you have built analytics or ML models trained on a consumer's CDR data, the deletion obligation may extend to those derived datasets — seek legal advice on your specific architecture
The CDR Rules distinguish between 'deleting' and 'de-identifying' data; de-identification may be permissible where deletion would destroy an obligation-critical audit record — the data must meet the Privacy Act standard for de-identification to use this option
Consent expiry (end of 12-month period) triggers the same deletion obligation as explicit withdrawal; many implementations miss the expiry-triggered deletion because they only handle explicit PSU withdrawal events
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