The gray zone of customer service

Most banks are interested in interacting with retail customers, both to retain old ones and to attract new ones. Therefore, the desire of MTS-Bank, which is actively working in the retail lending segment, to get to know the current and potential consumers of its products is not surprising. From the tender published recently, it became known that the bank plans to create a platform that would allow access to all relevant data from various sources, “containing valuable information about individuals and legal entities,” in one interface. The platform must provide a single detailed response for all sources and data specified in the request, and a phone number or full name is sufficient for the request.

But here of particular interest are the sources in which this information will be searched. For example, it is supposed to use the Get Contact service (and NumBuster, CallApp and others similar to it), by which you can find how the client is recorded in the phone books of other clients. In addition, the bank plans to check accounts and announcements on the Yula and Avito services, the presence of accounts in Russian Railways, airlines, electronic wallets (Qiwi, Webmoney, Eleksnet, VKPay). It does not neglect the traditional ways, using search engines and major social networks.

The bank noted that they want to “conduct an experiment to simplify and improve the customer journey, in order to verify the correctness of data entry when applying for their products, and to understand whether there are similar services on the market.” The idea itself to systematize such a service is not uncommon, the interlocutor of Kommersant notes in one of the large banks, not excluding that the largest banks have such platforms.

But for lawyers, the list of sources from which the bank plans to extract information raises many questions. Most likely, the service will be built on automatic parsing of information from Internet resources, which can potentially violate both contractual restrictions on sites and intellectual rights to databases, explains Comply Managing Partner Artem Dmitriev. Meanwhile, this practice is in a gray area. In fact, a person’s profile is being collected, which may contain quite sensitive information, which means that the consent and data processing policy of MTS Bank should describe in sufficient detail and clearly the purposes of data processing, types of data collected and sources for collection.

Collecting such an array of data in the end, most likely, will allow you to fulfill sales KPIs. However, having been denied a loan, the client is unlikely to immediately understand that the reason could be a published post on a social network, or they refused because someone on your phone has a negative nickname “does not repay debts”.