Data, ethics and the creepy line

For Emma Gray, chief data officer at ANZ, data is an inseparable part of the customer experience - but equally as important is how financial institutions use it.

"There’s no morality in just complying with the law to protect our own interests.” - Michelle Pinheiro

“Banks have access to an enormous amount of privileged customer data and while we want to use that data to provide better experiences and outcomes for our customers, we have a responsibility to do the right thing,” she says.

For Gray, the bigger question is: what guidelines are needed to make sure customer data is used for good? 

ANZ’s head of data governance Michelle Pinheiro says when it comes to customers, the financial services sector has to approach data through a “lens of harm”.

“We don’t put them in physical harm, we don’t do them emotional harm and we also don’t do them financial harm as well,” she says.

“We want to make sure firstly that we’re always using our customers data not just for our commercial advantage only.”

“I always like to use the test or the measure of, ‘Would I be comfortable disclosing to the customer how we are using their data if they were sitting across the table from me?’”

The creepy line

Pinheiro says 21^st-century organisations are the ones going to win the customer experience battle. Securing their custom – and “winning” - is about understanding them better and having more-personalised products and services, she says.

But when it comes to what customers want, there is a fine line between being pre-emptive and being “creepy”.

“It’s a really interesting point because what I think we haven’t really worked through as a society is that some consumers in some circumstances and contexts will expect the provider to be ahead of the game,” Pinheiro says.

“So if your phone prompts you with a weather forecast for Melbourne because your calendar shows you’re travelling tomorrow that’s ok because that’s what we expect.”

The rules may not be the same for a bank, Gray says – and what is appropriate will ultimately depend on the customer.

“The role banks play and how we step through use of social media, for example, is a huge issue because our role is to be the trusted custodian of hopes and dreams expressed in financial ways,” she says.  

“To some consumers, we have the right to engage with them social media but for others we do not.  What we decide from a principle standpoint and how we execute that is really important.”

Gray says the increasing role of algorithms in banking was an obvious area for customers to wonder about the role their personal data plays – but in reality, human decision making (and therefore morality) still played a huge part.

“I think the way that we’ve tried to construct ANZ’s algorithms means anyone can look at them and say ‘I understand what that means for me’,” she says. 

“‘Algorithms’ is such a fancy word, a bunch of computer code nobody really understands. But code is just people making decisions. Ordering what you want for dinner tonight is just an algorithm.” 

“It’s just you processing. ‘How many people are we having for dinner?’ and ‘Did we have fish last night?’ Those are just algorithms in your head. “

Principles

Having working with the Board of Data Governance Australia on their principled and ethical guidelines, Pinheiro has deep experience in the area – experience she says she has applied at ANZ.

“There’s no morality in just complying with the law to protect our own interests,” she says. “We want to set the bar higher, and we are doing this because it’s the right thing for our customers and not because we are driven purely by compliance.”

“In that transparency we’ll gain more customer trust and from that they’ll give us more information so they’ll get even better products and services. It’s a really compounding thing.”

Gray says the way ANZ thinks about principled data use is important and may serve as a differentiator for customers.

“In my view there are lots of organisations looking at data and excited about the things they get to do with it,” she says. “But they’re not necessarily doing so with a clear, purpose-driven ethical framework in mind.”

 Joanna Jordan is a bluenotes contributor