Consent lifecycle
Creation
When you click Connect on a bank, we redirect you to Fiskil’s hosted consent screen. Before the redirect, we display a disclosure stating that Redbark operates as a CDR Representative of Fiskil and that Fiskil will collect and disclose your CDR data to Redbark on your behalf. This satisfies clause 3.2 of our CDR Representative Arrangement (the “no holding out, required disclosure” obligation). At Fiskil’s screen you select your bank, authenticate with the bank’s own login, and choose:- Which data categories to share (accounts, transactions, balances, payees, and so on)
- The sharing period (up to the 12-month maximum under CDR Rule 4.14)
The consent record
Each consent in our database stores:- The Fiskil consent ID
- The bank connection it applies to
- The data categories granted
- The purpose (“Access to banking data for transaction sync”)
- The creation and expiry timestamps
- Its current status (active, withdrawn, expired) with an audit trail of every state change
Expiry and renewal
The CDR Rules cap consent duration at 12 months. We run a daily scheduled job that sends an advance email 90 days before a consent expires, so you have time to renew before sync stops. When a consent expires, all syncs that depend on it stop automatically. To restore access, connect the bank again from the connections page to start a fresh 12-month consent.Withdrawal
You can withdraw any active consent at any time from the Consents page. Withdrawal is real-time:- We call Fiskil’s consent-revocation API
- We disable every sync that depends on the consent
- We queue deletion of the associated connection, accounts, and tokens
- We record the state change in the audit log
What we store, and what we don’t
We do store
- Account metadata — institution name, account type, masked account number. Enough to render the UI and map accounts to destinations.
- Consent metadata — status, purpose, data categories, expiry, state-change history.
- Encrypted tokens — OAuth and provider tokens, encrypted at rest with AES-256-GCM and unique random IVs.
- An audit log — every state-changing action records who, what, when, and which entity.
We do not store
- Transaction amounts, dates, descriptions, merchant names, or payee names
- Account balances
- Raw CDR payloads from Fiskil
- Your bank credentials (you enter those directly at the bank)
Destinations
When you configure a destination, you’re directing Redbark to deliver your transaction data to that destination. Once delivered, the data lives in your own account with that provider under their terms and falls outside the CDR framework. Our destination setup flow shows a disclosure to that effect before you complete the setup. This covers the “clear and informed choice” standard from the ACCC’s Third-party data sharing use cases guidance.Logs, errors, and analytics
CDR and PII data is scrubbed before it leaves our runtime:- Sentry runs every error through a redaction layer that replaces values for known CDR transaction fields, PII, and secret keys.
- Pino logs (which flow to Axiom via the Vercel log drain) redact the same fields at source.
- PostHog analytics has DOM autocapture and session recording disabled. We rely on explicit
trackEventcalls for analytics, which never include banking data.
Deletion
Delete a single connection
Disconnect a bank from the connections page. We withdraw the consent at Fiskil, disable dependent syncs, and delete the connection and its tokens.Delete your account
From the Settings page, clicking Delete Account triggers a full cascade:- Withdraw every active CDR consent at Fiskil (and Akahu, SnapTrade if applicable)
- Delete the provider-side end user at each provider
- Cancel your Stripe subscription
- Revoke OAuth tokens for every connected destination
- Remove your data from our database
Your rights
Under Australian privacy law and the CDR Rules, you can:- Withdraw consent at any time
- Delete your account at any time
- Request access to the personal information we hold about you by emailing privacy@redbark.co (we respond within 30 days)
- Request correction of inaccurate personal information at the same address
- Lodge a privacy complaint with the OAIC at oaic.gov.au
- Lodge a CDR complaint via Fiskil’s complaints process; Fiskil’s external dispute resolution body is AFCA (member 83521) at afca.org.au