In our last blog about consumer data access, we discussed the challenges that startups face when it comes to accessing their users’ financial data in order to build innovative tools. Today, we’re back to share that the Financial Health Network has just published a new report on this topic: Liability, Transparency and Consumer Control in Data Sharing.
Building upon our 2016 report, in which we discussed overall principles around data sharing, we are now going a level deeper to provide concrete recommendations. Specifically, we discuss the need for a liability framework, continuity in consumer communication and control, and universality of design.
A few quick takeaways:
Liability concerns have proven to be a massive barrier to coordination, especially given the complex regulatory framework in which many of the participants operate. The current situation is relatively opaque, with participants largely uncertain of how liability would spread in the context of a misstep. In our discussions with key players, this concern is of overriding importance, and we have suggested several approaches to tackling this challenge.
Continuity is critical to a consumer’s ability to control how their data are shared and to ensure clear communication around such sharing. Consumers must be informed about the relationships into which they are entering and have the ability to manage those relationships transparently. Especially given the increased focus on privacy and security of late, we encourage market participants to provide consumers with fine-grained control over their preferences while ensuring that access can be revoked at any time and for any reason.
Any framework must be generic and ubiquitous. If the standards cannot apply across the entire landscape, they will provide extremely limited value. It is especially critical that small financial institutions and nonprofits can participate, despite not having large IT departments capable of implementing sophisticated processes.
You can be sure we’ll continue this important discussion. In the meantime, check out the full report here.