Responsible Banking Framework: How we want you to build trust

What’s this?

Responsible use of customer and employee data is a priority issue for banks. Our Responsible Banking Framework is used by us — and can be used by you — to:

• Identify potential to give rise to risk and harm to your customers, employees, society, and the environment: As the digital revolution continues and institutions embrace increasingly advanced emerging technologies, various risks can arise on new product lines or services, from legal and regulatory, to perceptions of injustice and unfairness. Look at our framework on Potential Risks and Potential Harm to consider what issues may arise on your data use case.
• Remain mindful of what opportunities are at stake: As laws and regulations add further requirements on institutions to implement procedures and systems to ensure responsible use of data, they should consider the opportunity cost. Run through the “Opportunities at stake” list to help maintain a balanced approach to commercial considerations and risk.
• Consider the technological mega trends driving a product line: Often bank products or services are considered with a narrow focus, or even as a reaction to competitor products. Consider the mega trends and levels of technology maturity to “step-back” and look at the bigger picture.
• Consider the Known Data Universe: The amount of data collected for each individual is immense. Understand what type of data points a product proposes to use, as well as the potential inferences and deductions that can be made in the data use case.
• Guide decision-making: The job of executive teams is to balance the trade-offs between risks and opportunities. But often one does not have to come at a cost of the other. Use our set of guiding principles to help lessen the potential risks whilst maximizing the business benefit. This will help you ask “should we proceed with this product or service?”, as opposed to “can”.
• Consider mitigating controls and residual risks: There are a plethora of potential controls that can be implemented in business solutioning to reduce potential exposure of society, environment, and the business to risks or harm. Take time to go through our list of suggestions, and then consider what residual risk may remain after a control is implemented.

Consider this framework a living and changing document: we will continue to update it with use cases and examples as technology and regulation evolves.

Why is this important?

• TRUST is the new battleground for existing and future financial institutions, society, and governments. Banks that maintain the trust of their customers will be rewarded; those that do not will be starved of the data that is needed to make use of these emerging technologies.
• Failure to safeguard customer data or use it appropriately is an expensive mistake that erodes a firm’s competitiveness and business viability.
• CEOs have a difficult balance to strike: too much red-tape and conservative decision-making stifles agility and innovation.

Responsible Banking Framework

Figure 1: Responsible Banking Framework, Summary of Analysis Framework. Trust Me If You Can (2019). Analysis taken from our article on Social Credit Scores.

Figure 2: Opportunities at Stake, Responsible Banking Framework, Trust Me If You Can (2019)

Figure 3: Technology Trends and Capabilities, Trust Me If You Can (2019)

Figure 4: Known Data Universe, Responsible Banking Framework, Trust Me If You Can (2019)

Figure 5: Potential Risks, Responsible Banking Framework, Trust Me If You Can (2019)

Figure 6: Potential Harm, Responsible Banking Framework, Trust Me if You Can (2019)

Figure 7: Capability to Mitigate Risk and Harm, Responsible Banking Framework, Trust Me If You Can (2019)