An adult (parent, guardian) provides consent on behalf of a child. The child is a client, the adult is not.
A company officer provides consent on behalf of an organization
For both scenarios the following five cases are material:
Both consent owner and consent giver are managed by MDM (currently supported)
Both consent owner and consent giver are managed by the same system outside of MDM (currently supported)
Consent owner is managed by MDM, but consent giver is managed in a CIF outside MDM (not currently supported)
Consent giver is managed by MDM, but consent owner is managed in a CIF outside MDM (not currently supported)
Consent owner and consent giver are managed in different CIFS outside MDM
Scenario 1) is very conceivable, especially if the adult is a guardian or a representative of the state - they may well do their banking elsewhere.
For scenario 2), given organizations can't speak or act independently, there will always be a human consent giver different from the consent owner, and the legal requirements to capture the identity of the giver are not difficult to extrapolate. In the specific case of RBC, for this scenario, consent owner would be managed by MDM, but consent giver would be managed outside MDM
|Who would benefit from this IDEA?||Companies that have grown by acquisition are likely to have their collection of involved parties fractured across different systems and would stand to benefit. I expect such companies are also a strong part of the target market for an offering like MDM. For RBC specifically, this change would allow us bring the second scenario into MDM|
How should it work?
Currently CONSENT.ENFORCEMENT_TYPE and CONSENT.SOURCE_IDENT_TP_CD describe the disposition of BOTH consent owner and consent giver profiles. We need such attributes for each of consent owner and consent giver, with corresponding support in the relevant transactions
As enumerated above this change would enable all five of the material cases, opening the capability up to the full scope of possibilities in the market.
|Priority Justification||Government of Canada Bill C86 brings much more stringent requirements around consent into effect December 2021.|
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