Overloading of banking language for scopes / data clusters

[JohnHarrison-Truelayer]

Description

The data standards language in the Banking Language section differs depending on whether the customer is a business customer or an individual customer. This is problematic at the time that collection consent is requested. This is because data recipients will be unable to determine which case will apply until they call the Get Customer or Get Customer Detail endpoint, and this is impossible until the authorisation process has been completed.

Area Affected

The Banking Language section and the Data Language Standards: Common section.

Change Proposed

In the short term, we recommend that the Data Language Standards: Common section be updated to reflect the issue, perhaps by stating “Data Recipients and Data Holders SHOULD use the appropriate data standards language for business consumers as denoted with an '*' for the relevant data.” rather than the current MUST. This approach would align with the statement that “Data recipients SHOULD identify whether a consumer is an individual or business customers in order to surface the correct data language”.

In the long term, we recommend DSB determine an appropriate way for the permission language to be aligned between data holders and data recipients. This might involve a re-alignment to scopes, but also potentially to fine-grained consent attributes (such as requests for e.g. open accounts or business accounts only) as part of the FAPI 2.0 transition.