Starling Bank – Supplementary written evidence (GAM0122)
The committee asked with regards to the sharing of customer data whether or not this is inhibited by GDPR rules.
Starling Bank firmly believes that customers are the owners of their own data and we do not share their data with anyone unless customers expressly allow it or unless required to do so by law.
GDPR is in place to better protect data and its sharing, giving rights to the data subject and allowing them to restrict its use and obliging the collectors and processors of data to be clear about how it will be used.
We are clear about this in our Privacy Notice where we confirm we'll share it with law enforcement upon request and fraud agencies to prevent fraud.
Under a number of UK Acts a broad range of parties including HMT, SFO, Security Services, Police, Local Authorities, DWP, CSA and the Regulators can all request data.
Starling Bank assesses each request in accordance with our policies before data is provided.
With regard to the sharing of fraud data, this is permitted to prevent financial crime and protect the interests of our customers and others.
The Committee was also interested in the number of customers who have enabled the gambling block feature and also the number of customers who have disabled it.
In my evidence to the committee I said that at present 17% of our account holders have enabled the gambling block.
There are a number of reasons a customer may choose to enable this feature and whilst it serves as a useful tool for customers who feel that they are unhappy with the amount they are spending on gambling, it is also used by customers who may not gamble often or even at all and simply enable it as matter of course for that reason. Equally parents may enable the block as an additional layer of protection.
Beyond those who have the block enabled we do not currently actively monitor the amount of people who have disabled the block. The committee was interested in how many customers typically would activate the block within one month of opening a Starling account. We’ve looked at the last month’s data and 12% of customers who have opened an account in the last month have activated the block.
The committee was interested in our process for approving credit and if in that approval process we would be able to see if a customer had taken out a payday loan for example.
Credit reference agencies hold a range of information on customers ranging from a customer’s name, current address and previous addresses from the past six years, and whether they are registered on the electoral roll.
They may also hold information on the number of accounts customers have had in the past six years, and when they opened them, their regular payments, including any missed or late payments and whether they have had a default, CCJ, IVA or bankruptcy in the past six years.
When assessing someone’s creditworthiness we search two credit reference agencies to maximise how much information we're able to gather on each individual customer. We use TransUnion and Equifax for retail searches. We also use Experian for commercial searches.
As part of this we are able to see all new external debts that customers take out, as long as that lender is supplying information to the credit bureau we search.
We can't see the specific lender with whom the customer has taken out credit, unless we see a repayment to a specific lender from current account or open banking information we hold on a customer.
It can be difficult to distinguish between payday loans and other types of credit in this process and subsequently don’t currently make that distinction in our credit strategy.
The committee also asked what would be a good approach in the retail banking sector with regards to introducing affordability checks whilst respecting confidentiality and client accountability to support customers with issues such as gambling.
As I said in my evidence, I accept that the banking sector has a role to play in helping people manage their finances and avoid getting into financial difficulty. This is why Starling bank was established, to help people manage their money better.
Whilst the gambling operators are obviously best placed to know if their customers are struggling with gambling, and to provide the appropriate help and support, the banking sector can also support through the use of technology like the introduction of gambling blocks to put customers in greater control.
It would be helpful for the banking sector to work together more collaboratively on this issue and I will be asking UK Finance to do more to bring the sector together to discuss this and we will work with them on it.
This work could include consideration of:
- an agreed industry standard with regards to gambling block technology and affordability checks; and
- the sharing of best practice across operators who have implemented blocking features;
We would be happy to be part of wider cross-industry discussions, including on loot boxes and skins betting, as well as on measures that can be used to block gambling for under 18s.
23 March 2020