Registers a new access record on behalf of a Controller. Returns 201 and
an access-token containing the new access key (ak), plus a Location
header pointing to the created resource.
All records use the same AccessRecord schema. The processing.legal-basis
value determines which additional fields are expected:
notice and access-event.consent.lia-reference on the lead controller
entry; set notice and access-event.consent to null.statutory-reference on the
lead controller entry; set notice and access-event.consent to null.notice and access-event.consent to null.Historic records may be submitted — access-event.registered-at may predate
record-metadata.created-at.
If the DCC has previously submitted a DISCOVERED record for the same MPxN
and organisation, the register will link the two records on creation. The
DISCOVERED record is retained for audit; the new full record becomes ACTIVE.
To update an existing record use PUT /access-records/{ak}.
Cross-DUID re-identification: To create an Access Record linked to an Identity Record originally created by another Data User, include a reidentification-token field in the request body (alongside the standard AccessRecord fields, without record-metadata.identity-record-ref). Obtain the token via POST /identity-records/reidentify. The register validates the token and resolves the ir internally.
JWT from GET /auth/token. Pass as Authorization: Bearer <token>. Expires after 7200s.
An AccessRecord. All legal bases use this same schema.
A data access record covering all lawful bases. The same schema is used
regardless of processing.legal-basis. The notice field and
access-event.consent sub-object are null for non-consent records and
populated for consent records.
ISO 27560 Section 1 — Record Metadata
record-identifier and created-at are assigned by the register on creation
and returned in responses; they must not be supplied in request bodies.
identity-record-ref links this access record to the Identity Record that
holds the person-property relationship (PII principal, move-in date, address,
and identity verification evidence). Supply the ir key returned when the
Identity Record was created. The linked Identity Record must have been
registered by the same authenticated Data User.
identity-record-ref is required when registering a new Access Record in the standard flow. It may be omitted when a reidentification-token is supplied in the POST /access-records request body — the register resolves the ir internally from the validated token.
Populated for consent-based records; null for all other legal bases.
ISO 27560 Section 3 — Processing Fields
Defines the shared scope and legal basis of data access. These fields apply to the access registration as a whole regardless of how many controllers are involved.
Per-controller compliance fields — privacy-rights-url, lia-reference,
statutory-reference, and storage-conditions — are held on each
Controller entry within record-metadata.controller-arrangement, where
each controller bears individual accountability.
legal-basis applies to all controllers in the arrangement. For joint
arrangements, all controllers must share the same legal basis — if purposes
or bases differ, separate Access Records are required.
ISO 27560 Section 4 — Access Event Fields
Records when access was registered, its lifecycle state and duration, and (for consent records) the specific details of how consent was expressed.
registered-at serves as the canonical event timestamp for all record types —
for consent records it is the date the customer gave consent; for non-consent
records it is the date the Controller registered their access.
revoked-at is set by the register on revocation and must not be supplied
in request bodies.
consent is required when legal-basis is uk-consent or uk-explicit-consent. It must be omitted or null for all other legal bases (uk-public-task, uk-legitimate-interests, uk-legal-obligation, uk-contract).
Cross-DUID only. A confirmed token-ref obtained via POST /identity-records/reidentify. When supplied, identity-record-ref in record-metadata must be omitted — the register resolves the ir internally. The token is single-use, scoped to the initiating Data User, and expires one hour after issuance.