CDR Policy

Purpose

This Policy sets out how Angle Finance complies with its obligations as a data holder under the Consumer Data Right (CDR) regime, as established under Part IVD of the Competition and Consumer Act 2010 (Cth) and the Competition and Consumer (Consumer Data Right) Rules 2020 (Cth).

This Policy applies only to Product Reference Data (PRD) and does not apply to consumer data, customer dashboards, or data sharing based on customer authorisation.

Scope

In Scope

This Policy applies to:

  • Product Reference Data for covered products offered by Angle Finance that fall within scope of the CDR Rules.
  • Publication, accuracy, availability, and update of PRD through CDR‑compliant channels.
  • Governance, accountability, and complaints handling relating to PRD obligations.

Out of Scope

This Policy does not apply to:

  • Consumer data requests
  • Customer‑authorised data sharing
  • Consumer dashboards
  • Joint account management
  • Disclosure of transaction data or customer‑specific information

Angle Finance is currently excluded from consumer data sharing obligations because it does not provide digital or online access to customers in respect of covered products. If digital access is introduced, or if the law changes to remove this exclusion, this Policy will be reviewed.

Regulatory Framework

Angle Finance’s PRD obligations arise under:

  • Part IVD of the Competition and Consumer Act 2010 (Cth)
  • The Competition and Consumer (Consumer Data Right) Rules 2020 (Cth)
  • Applicable CDR Standards (including technical and data standards)
  • ACCC compliance guidance for data holders in the banking and non‑bank lending sectors

Role of Angle Finance as a Data Holder

Angle Finance is a relevant non‑bank lender and acts as a data holder for the purposes of Product Reference Data obligations under the CDR regime.

As a data holder, Angle Finance is required to:

  • Make required PRD publicly available in a machine‑readable, standardised format
  • Ensure PRD is accurate, complete, and up to date
  • Notify and publish changes to PRD within prescribed timeframes
  • Maintain appropriate systems, controls, and governance to support compliance

Product Reference Data (PRD)

What constitutes PRD

Product Reference Data includes information about products that is:

  • Publicly offered or advertised
  • Not customer‑specific
  • Prescribed under the CDR Rules and Data Standards

This may include, for example:

  • Product names and categories
  • Pricing ranges, rates, and fees
  • Key eligibility criteria
  • Terms and conditions (including links to disclosure documents)
  • Features relevant to comparison between products

Publication and Availability

Angle Finance will:

  • Publish PRD in accordance with CDR Rules and Standards
  • Make PRD available via approved CDR APIs or other compliant mechanisms
  • Ensure PRD is presented in a consistent and standardised format

Accuracy and Updates

Angle Finance will:

  • Take reasonable steps to ensure PRD is accurate and not misleading
  • Implement controls to detect changes to pricing, terms, or features
  • Update PRD within required timeframes once a change occurs
  • Maintain internal processes to approve, validate, and release PRD updates

Consumer Data and Customer Access

Angle Finance does not currently provide:

  • Online account access
  • Digital dashboards
  • Customer self‑service portals

Accordingly, Angle Finance is not required at this time to:

  • Receive or respond to consumer data requests
  • Build or maintain a consumer dashboard
  • Comply with joint account data sharing or authorisation flows

This position is monitored on an ongoing basis and will be reassessed if:

  • Digital customer access is introduced; or
  • Legislative or regulatory changes remove the current exclusion

Governance and Accountability

Compliance with this Policy is overseen by the risk and compliance and technology teams.

Material incidents or breaches are escalated in accordance with Angle Finance’s incident management framework.

Complaints and Enquiries

Angle Finance maintains an internal dispute resolution process to address:

  • Complaints relating to PRD accuracy or availability
  • CDR‑related enquiries from regulators or stakeholders

Complaints will be handled in a timely, transparent, and fair manner, consistent with regulatory expectations applicable to PRD obligations.

Training and Awareness

Relevant staff involved in:

  • Product design
  • Pricing
  • Disclosure
  • Technology and data publication

will receive appropriate training on PRD obligations and this Policy.

Review and Maintenance

This Policy will be:

  • Reviewed at least every 3 years
  • Updated sooner if there are material changes to:
    • CDR Rules or Standards
    • ACCC guidance
    • Angle Finance’s customer access model