Response to discussion Paper on innovative uses of consumer data by financial institutions

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1. In what capacity (i.e. consumer, financial institution, technology providers, etc.) have you had experience with innovative uses of consumer data?

De Nederlandsche Bank (DNB) is the Dutch central bank. In that capacity, DNB chairs the National Forum on the Payment System (Payments Forum, in Dutch: Maatschappelijk Overleg Betalingsverkeer). In 2015, the Payments Forum commissioned independent research into the views of the Dutch on the use of payment data by banks and other parties. The survey was held by the independent research agency Motivaction among 1,259 Dutch citizens aged between 18 and 80. The survey results were published in September 2015 and are only available in Dutch; below you find a summary/press release in English.

SUMMARY/PRESS RELEASE

The Dutch citizens accept the commercial use of payment data by banks only to a limited extent. Acceptance is higher with regard to the use of payment data by banks for such purposes as meeting the duty of care, enhancing security and improving service delivery.

In a nutshell, this has emerged from a survey commissioned by the National Forum on the Payment System (Payments Forum) into the views of the Dutch of the use of payment data by banks and other parties . Independent research agency Motivaction held the online survey between 16 and 22 September 2015 among 1,259 Dutch citizens aged between 18 and 80 through its StemPuntpanel. Its results are representative for the characteristics age, gender, education, region and mentality (i.e. Motivaction’s values and lifestyle model). At the heart of the survey were questions about the use of data by banks for specific purposes, described in nine different scenarios.

Knowledge of the use of payment data
The Dutch have limited knowledge of how banks use their payment data. Of all respondents, 45% said they did not know what the banks use their payment data for. The remaining 55% assumed that banks use payment data to process payments and check data and bank balances. When presented with a number of specific scenarios – some of them fictitious – the Dutch appeared to be unsure whether their own bank uses data for these purposes.

Acceptance of data use
What banks do with payment data is largely within acceptable limits, according to the Dutch. The percentage of Dutch who consider it acceptable for banks to use payment data exceeds the percentage who believe banks actually do. Dutch respondents find it more acceptable that data is used for general, non-commercial purposes, such as meeting statutory and other obligations, enhancing security and combating fraud (80%), improving service delivery (68%) or identifying trends (47%), compared with purposes targeting them individually, such as providing advice (28%) or making special offers (3-12%, depending on the exact scenario).

The majority (64-90%) do not find it acceptable for a bank or other party to use payment data for commercial purposes if this entails making special offers on the basis of an analysis of payment data. Objections raised most often were the lack of consent for using the payment data (55-76%), while the resulting invasion of privacy (41-70%) also weighed heavily. Other considerations were that the bank did not inform people of their payment data being used (22-41%) and that people were not interested in getting special offers (29-45%).

Acceptance increases if a bank puts its customers in charge. In many situations, asking for consent may make it more acceptable to use payment data. This does not apply, however, to passing on or selling payment data to allow other parties to make targeted offers, with 55-66% not accepting this under any circumstances.

What people do if they do not accept the use of their data
If people do not agree to the use of their payment data, they mostly contact their bank (percentages up to 68%). They less frequently inform others (up to 33%), switch banks (up to 42%) or make more cash payments (up to 17%).

Use of data by other parties
The use of payment data by banks is accepted more readily than the use by other parties for general purposes, such as enhancing security, improving service delivery and identifying trends. Acceptance of the use of data by other parties to make targeted commercial offers is also low, but slightly higher than the use of payment data by banks.

The text of the press release is also available at http://www.dnb.nl/en/binaries/Summary%20-%20Press%20Release_tcm47-334532.pdf?2016062714

2. Based on your knowledge, what types of consumer data do financial institutions use most?

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3. Based on your knowledge, what sources of consumer data do financial institutions rely on most?

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4. Based on your knowledge, for what purposes do financial institutions use consumer data most?

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5. How do you picture the evolution of the use of consumer data by financial institutions in the upcoming years? How do you think this will affect the market?

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6. Do you consider the potential benefits described in this chapter to be complete and accurate? If not, what other benefits do you consider should be included?

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7. Are you aware of any barriers that prevent financial institutions from using consumer data in a beneficial way? If so, what are these barriers?

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8. Do you consider the potential risks described in this chapter to be complete and accurate? If not, what other risks do you consider should be included?

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9. Have you observed any of these risks materialising? If so, please provide examples.

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De Nederlandsche Bank

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Dutch Central bank