The ethical use of customer data

We are seeing growing interest among regulators, businesses, MPs, think tanks and the media in how data is used or ?data ethics?. Among all these actors, there is recognition that we need to ensure that innovation in data analytics and artificial intelligence (AI) is used in ways that benefit consumers and society. For example, recently we have seen:

  • The publication of the first two-year strategy of the Centre for Data Ethics and Innovation
  • The publication of the Furman review (though this looked at a broad suite of issues, including competition)
  • The European Commission's high-level expert on artificial intelligence issued a consultation on ethical AI guidelines

As more industries leverage data analytics and AI to a greater degree, the importance of data ethics will grow. As in other sectors, this is also true in financial services. Regulated firms have strong internal compliance structures and experience with managing risks to the business and to customers - not just through FCA rules, but also with data protection and the newly-implemented GDPR. This is a strong starting place from which to build a data ethics framework, with firms already encouraged to think carefully about questions of fairness and transparency, for example.

But technology moves fast, and regulation might not always keep up. Beyond compliance with the official rules, entrenching data ethics into the culture of firms will help ensure that not only are high standards maintained, but customers? rights and interests are protected - even if the tech has moved beyond what was anticipated at the time regulation was drafted. Some firms are advanced in building a suitable culture and structures, while others will have a longer way to go.

UK Finance has collaborated with KPMG to produce a paper on data ethics, setting out some guiding principles and proposing potential first steps firms can take to start embedding data ethics within their organisations.

This is an initial broad-strokes approach to the topic and the thinking among all actors will no doubt advance further from here. New technologies and use cases will keep emerging - and each brings its own subtleties and challenges. But by establishing the right culture and ensuring that the right questions get asked as new products and tools develop, firms will be well-placed to manage these.