Who owns the customer data and who’s responsible for data? Who should be?
Who should be, so that’s a big question! As a bank, Barclays, generally speaking, has a very conservative view on data privacy. Even if we feel the data belongs to the bank, we always question it. Compared to my previous industry and the internet space, the approach is much more conservative and much more on the side of caution.
We have three basic principles when it comes to privacy. The first one is about opt-in: if we’re going to use the data of a customer or a company, there needs to be very clear disclosure and very clear opt-in. A clear opt-in leads to the second principle, that you have to have an economic exchange of value so when a customer or a company actually opts in, they have a tangible benefit. I will give you a quick example: In the personal bank, we have relationships with certain providers such as travel providers, energy providers, and so on. The way we utilize the data and allow our consumers to benefit from it is by saying, for example, we have these relationships and if we think from your data that you’re interested in travel or you travel often, and if you book through let’s say Expedia, you actually get 5% cash back in your account, once you follow the links through us and do the trip. We will say, we can actually save you direct money on your bill with the energy company if you actually go through this relationship.
The third principle is one where we always stay on the side of preserving anonymity. One of the services we provide to our small businesses and our corporate clients is insights into what their customers are doing. Let me start with a public example of members of the parliament, where we actually generate reports in the UK to talk about their jurisdictions and spend data in the local ecosystem. Barclays sees so much of the spend data because of our point of sale presence and our credit card and debit cards (in the UK, consumers use a lot of debit cards, much more than credit). We actually get a nice view of this spend, the trends, where the consumers are going, what’s picking up, what’s coming down. We provide that to the members of parliament as a service that says, within your district, this is what’s happening – there’s more spend on these categories, and so on. But if we report the average or aggregate spend dropping below 50 individuals, when usually they are in the thousands, we just don’t report, because the fear is that at a level of less than 50, you may be able to start triangulating on one individual.
I can tell you theoretically from a data perspective that limit is too conservative. My usual argument is you’re safe at five or 10, but being a conservative 300-year-old bank, 50 is extremely safe.