In Focus Risk
>> Left-right: Martin Parr; Patrick Langley; Peter Malarkey; Russ Barrett; Thomas Chapman
there can be a tendency not to talk to them, and they will stay remain on the
base, but if you prod them, it might spark off other things as well. It is like e-mailing people and tempting them with your unsubscribe button at the bottom. A certain percentage of people will click to unsubscribe, and if you mail them enough, then you will lose customers unless you offer them real customer value. So, in some ways, things are much better now.
PL: For whatever reason, time or cultural, we, as credit management, have probably not talked enough to marketing, so it is another positive side of the GDPR exercise.
TC: The portability piece will be important. You now have various apps like Mint and challenger banks like Starling using modern platforms to deliver a holistic financial experience. The whole concept is around data being portable – your savings, pension, current account, insurance, personal loan, car finance, and mortgage could all be with different providers – now you can easily realise them all in one place. This could be used to solve the marketing issue as you can satisfy the express-consent element within this platform, although what is in it for the customer, and how do you hold their attention? Most of us use Google services like search, e-mail, and Youtube seemingly for free – the reality is that our interactions generate data that is worth something to respective advertisers. In essence, Google offers an exchange of your data for their services. In addition, Google also have to remain relevant and this is what keeps people coming back. Setting up a platform that consolidates people’s financial world is only the first step – you keep them coming back by offering meaningful insight around
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their spending habits and how this might impact, or with slight modification benefit, their overall life goals. It is an appreciation of how your gambling or shopaholic tendencies can impact you buying your first home or that dream holiday to the Grand Canyon. If that dream holiday cannot wait, we can at least, based on the data, have a sensible conversation about an affordable credit option now and, in addition, let us ‘gamify’ the way you pay it back in order to avoid repayment fatigue. What we offer then, in exchange for potential to market and ability to understand behaviour and habits is an education in how to become fiscally responsible, more importantly how to start crossing things off the bucket list. Big Data holds such promise, and GDPR can be seen as another stumbling block on that journey. However, I personally embrace it, unchecked Big Data turns very quickly from dream to nightmare. In order to make forget requests and concerns over access to sensitive data easier to handle, we have introduced a notion of generalised tables, in addition to the sensitive tables. The sensitive customer tables are essentially a protected area only accessed with express permission, this is also a place where a purge can occur and not impact the transactional and snap- shot history elsewhere. If, for example, I am
doing analytical work around demographics, I do not care that this person is called Mr John Smith, and he lives at number 36, but I do care that he is male, between 45 and 55, lives in London. It is a simple concept, easy to realise from an architectural standpoint.
JD:We think that the biggest risks to the business is not the customer requesting the right to be forgotten, but your internal staff and contractors – how many people internally can access your data, copy it, leak it, sell it, or leave open access on their laptop? Your staff (it applies to their records) will know more about GDPR than anyone else when it comes to an employment dispute. Most customers, in truth, do not understand it and are not aware of the nuances of the new legislation.
MH: Something that we are now working through is unstructured data – where somebody just copies and pastes something into an e-mail that is not linked to the case- management system. That is another risk.
Something that we are now working through is unstructured data – where somebody just copies and pastes something into an e-mail that is not linked to the case-management system
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TC: Unstructured data is very interesting: the message that has gone out to the agent level is that you need to be aware of everything that you are writing down on the system and discussing via e-mail, keep it salient and factual, ask yourself if absolute identification in a given message is even required? From a system perspective, you do not need to generate notes where entry forms for specific and particular details like vulnerability logging or repayment-plan setup are provided. In essence, let us opt for input that occasions structured datasets or anonymous account ID-based comments that are, by definition, easier to deal with and do not require complex software solutions after the fact. CCR
May 2018
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