Updated @April 24, 2024
The Data Standards Body strives to create an accessible and inclusive CDR that is easier and simpler to access for everyone. This page provides an overview of how the DSB has developed CX research, standards and artefacts to help achieve this.
- Participants engaged in CX research
- Identity and diversity
- Financial situation
- CX research and community consultation outcomes and recommendations
- Consumer Policy Research Centre
- Accessibility Standards
- Data Language Standards
- CX guidelines and recommendations
- CX guidelines and artefacts that prioritise transparency
- Research recommendations concerning vulnerable joint account holders
- CX artefacts and open source assets
- CX Guidelines website
- Open source assets
- Design assets
- Coded assets
- Opportunities to support an accessible and inclusive CDR ecosystem
Participants engaged in CX research
From Q4 2018 to Q1 2024, 1035 unique consumer-participants have been engaged for CX research. 20 of these participants have been reengaged on 2+ occasions.
Research focused on recruiting consumers with differing attitudes, literacies, and access requirements, as well as those with varied backgrounds, needs and experiences. A wide range of characteristics were used to screen consumer-participants to span the broad and wide-ranging definitions of vulnerability used by industry and the community sector.
Identity and diversity
- 83 consumer-participants identified as having "accessibility needs" relating to physical; vision; hearing; speech or audio; and/or cognitive or learning limitations.
- 147 consumer-participants identified as an "older person". The Australian Bureau of Statistics generally classifies people over 65 as 'older'.
- 400 consumer-participants indicated Culturally and Linguistically Diverse (CALD) backgrounds by having a non-English speaking background, their parents having a non-English speaking background, and/or migrating to Australia from another country.
- 58 consumer-participants identified as being of "Aboriginal and/or Torres Strait Islander descent".
- 112 consumer-participants identified as "LGBTQI+".
Financial situation
- 318 consumer-participants indicated that they have experienced financial difficulty, had been in financial distress, or relied on government allowance.
- 15 consumer-participants indicated that they had closed a joint account after separation from a partner or had a "negative" relationship with someone they shared a joint account with.
CX research and community consultation outcomes and recommendations
Consumer Policy Research Centre
From 2020 to 2022, the Consumer Policy Research Centre (CPRC) was engaged to prepare a series of consumer research reports for the DSB, on subjects identified as being priority topics by DSB, CPRC, consumer advocates and community groups. The research reports derived findings through direct engagement with community sector stakeholders; reference to CPRC’s broader consumer policy research activities; and analysis of existing material relating to consumer experiences of data markets, the CDR, and consumer data reforms in other jurisdictions.
Research findings provided advice on consumer needs, expectations, risks and opportunities related to:
CPRC explained that consumer trust is crucial for CDR’s success. Trust can be perceived in a variety of ways:
- trust that the system is secure;
- trust that the law will protect consumers while using it;
- trust that businesses are delivering products and services that are safe, fair, and of good quality.
CPRC highlighted a number of priorities relating to consent, inclusion, and accountability, such as:
- the importance of considering joint account holders experiencing vulnerability;
- the information necessary to facilitate safe and responsible data sharing.
Vulnerability affects us all, at its broadest, consumer vulnerability refers to circumstances that cause difficulty in using markets or in receiving adequate products and services; or which heighten the risk of harm, detriment, or disadvantage to consumers. CPRC proposed principles that could help embed a duty of care for vulnerable consumers into the CDR regime, such as:
- CDR reforms should respond to consumer vulnerability as a positive opportunity to strengthen systems, build resilience, and grow trust;
- CDR services should provide people with agency to achieve ambitions, respond to crises, and manage their everyday consumer experience;
- CDR should not increase consumer vulnerability. No one should be put in a position where use of CDR products causes them significant harm or compromises their access to essential services;
- CDR should not shut people out from market participation. No one should be unfairly denied the opportunity to obtain benefits from CDR data sharing, or the means to challenge the legitimacy of negative outcomes.
Trusted adviser disclosure consent- CPRC noted that while trusted adviser disclosure consents could provide opportunities for financial counsellors and other non-profits to use consumer data for good, they identified some risks and concerns related to data leaving the CDR ecosystem; for example:
- increased susceptibility to privacy breaches and data leakage;
- lack of visibility regarding who has access to the data;
- consumers would be giving up the right to have their redundant CDR data deleted;
- ADRs may charge for the service and put functionality beyond the reach of non-profits unless exemptions created for vulnerable consumers.
Insight disclosure consent- CPRC suggested that vulnerable consumers would benefit from CDR Rules that require ADRs to provide consumers with a copy of any insights that are disclosed to other ADRs or to unaccredited third parties.
For additional and detailed findings, see CPRC reports.
Accessibility Standards
In June 2019, an accessibility review conducted by GippsTech recommended that CDR participants be required to comply with Web Content Accessibility Guidelines (WCAG) 2.1 (in particular guidelines 1.4, 2.1, 2.5, 3.1, and 3.3) to promote visual accessibility and readability. These recommendations informed the development of the CX Accessibility Standards, which require CDR participants to seek to comply with these aspects of the WCAG.
Data Language Standards
CX research with 306 consumer-participants was conducted to test and inform the development of data language standards for banking, energy and in anticipation of the telecommunications sectors introduction to the CDR. Out of these consumer-participants, almost half had diverse backgrounds, needs and experiences. The findings from 4 rounds of research (Q2 2019 to Q3 2022) were used to inform the Data Language Standards.
CX guidelines and recommendations
CX guidelines and artefacts that prioritise transparency
The research indicated that consumers who had experienced vulnerability or disadvantage were more inclined to be concerned about harm arising from data sharing. Consumer-participants explained that transparency would help alleviate these concerns. Transparency can be achieved through the use of accordions to segment, organise and surface important information without creating additional cognitive load for those who are not seeking additional details.
Research recommendations concerning vulnerable joint account holders
Research showed that those with joint accounts in "negative" relationships did not want the other account holder to be notified of data sharing activity. The rules allow joint account holders ‘flagged’ as vulnerable to be treated as individual account holders, as per CDR Rule 4.13(4). The CX standards build on this - the Notification Standards include specific provisions relating to joint account holders who may be experiencing vulnerability.
CX artefacts and open source assets
CX Guidelines website
The CX Guidelines website provide optional examples of key requirements and recommendations to help organisations build best practice consent models. The website was designed to be used by as many people as possible, and on various devices. In July 2023 all pages on the website were internally audited for accessibility compliance. At this time, the website was partially conformant to WCAG 2.1 level AA. Some known issues and limitations relate to the embedded Figma prototypes and Chrome browsers with JAWS on Windows. Read more on
Open source assets
In June 2022 the Consent Flow was audited by PwC's Indigenous Consulting and the Centre for Inclusive Design. At the time, open source assets relating to Consent, Authenticate and Authorise were partially conformant to WCAG 2.1 level AA.
The various elements reviewed included:
- Colour palette and accessible colour schemes that meet contrast requirements;
- Use of imagery and images of text;
- Typography and font selection;
- Layout and logical reading order for the content;
- Navigation, including drop down menus;
- On focus buttons and form fields;
- Heading levels and heading structure; and
- Error handling and alerts.
Design assets
Open Source design assets are provided in the form of Figma files for industry stakeholders. The open source design assets reflect the Consent Model, including some variations.
These design assets focus on visual presentation and readability, including:
- Intuitive reading order;
- Content written for an Australian year 7 reading level;
- Colour contrast ratio 4.5:1 for normal text;
- Consistent and responsive design patterns; and
- Predictable interactive elements.
These design assets do not tend to accessible code, for example:
- Text alternatives for non-text content;
- Keyboard functionality and other input modalities; and
- Content compatibility with assistive technologies.
Coded assets
The 2022 accessibility review conducted by PwC’s Indigenous Consulting resulted in a Proof of Concept (POC). The POC reflects the Consent Flow, showing the “happy path” for Consent, Authenticate and Authorise. The open-source code has been published for industry stakeholders on
The POC was tested with 10 consumer-participants, all with diverse demographic attributes and abilities. The findings from the research were used to inform Recommendation 7 (Review, prioritise and address issues of Transparency, Clarity and Understanding and Visibility in the Consent Flow) on Noting Paper 279 - Accessibility Improvement Plan.
Opportunities to support an accessible and inclusive CDR ecosystem
To ensure that an accessible and inclusive CDR is facilitated throughout its expansion and evolution, the DSB will continue to:
- Review and refine existing CX standards and artefacts in accordance with the Disability Discrimination Act (DDA), Australian Human Rights Commission’s (AHRC) guidance and WCAG. Read more on Noting Paper 279 - Accessibility Improvement Plan.
- Conduct CX research with consumers of diverse backgrounds, needs, experiences, abilities and vulnerabilities. Read more on ; andParticipant demographics
- Create and maintain CX artefacts that can be used by as many people as possible. Read more on .Accessibility statement
Quick links to CX Guidelines:
