When Barclays Bank’s Information Policy and Business Controls team scooped the Grand Prix at the DataIQ Talent Awards 2016, it came as a surprise to some. Despite its work picking up three category awards, it is fair to say that most of what the team does is not highly visibile to those outside the bank.
A visit to Barclays’ Canary Wharf headquarters building should tip off anybody about the changes underway at the company, however, of which the group-level information initiative is just one, internally-focused example. Walk into the front entrance and you are greeted by giant signage spelling out the bank’s core values - respect, integrity, service, excellence and stewardship.
“Those work so well in the data space,” notes Fedelma Good, director of information policy and business controls. Winner of the Data Professional (Client) award, she says the values spelled out at the entrance show the cultural transformation being undertaken by the bank. “Compliance is a journey everybody is on. We have established great foundations to keeping building on.”
That journey started back in 2010 (if not before) when Barclays was the creator of Think Privacy, a project aimed at raising awareness among frontline staff of the need to handle personal information with care. Collateral developed for the programme proved to be so useful that Barclays established the consortium which in turn put it into the public domain including via the ICO’s website so other organisations could adopt and benefit from it.
“Think Privacy was a foundation stone for Barclays, which was then augmented by Think Accuracy, which had a specific business focus around the validity of contact data,” recalls Good. “Think Accuracy was an important educational project because it got us seen as ‘sleeves rolled-up’ data practitioners.”
Originally centrally-driven, the project has become a business-as-usual tool focusing on three core messages - better security, better service and better communication. Led by Russell Barton, senior customer information manager, it secured him the Data Quality Programme award for maintaining the momentum and engagement with key stakeholders.
“Think Accuracy has been repeatedly used within the Barclays graduate programme because it is something they can develop new ideas within,” says Barton, who coaches and mentors graduates during their six-month assignment. They are encouraged to develop a stream of new ideas to keep the programme fresh, which has seen everything from online training and personal videos by regional directors through to quizzes and branded mugs.
The most significant stage in the journey was the creation of the Information Business in 2013 with the information policy and business controls team playing a key role in overseeing customer data governance. “The vision came from the CEO of Barclays UK, Ashok Vaswani,” says Good. “He saw that technology had moved on which enables data to be properly managed and utilised for the benefit of the customer and he wanted to drive us in that direction.”
She adds: “It was very visionary and very customer-centric and he has led us on the right journey. Ashok is very passionate about being digitally engaged. When you get that drive right from the very top, it really makes a difference.”
Externally, this drive is visible in initiatives like Digital Eagles, over 16,000 frontline staff located across the country who provide free technology advice to anyone, whether they are a Barclays customer or not. Internally, the Information Business has grown into a business-critical operation which aims to support data-driven initiatives while also ensuring group policies and legal compliance are adhered to.
“Until then, what we had been doing was a lot of good stuff - this department was formed to allow the organisation to focus on bringing all of those skills, resources and information engines together. My team was established as part of that, bringing key skills together and adding some new ones, like data scientists,” explains Good.
The Information Business team was built on four key operations. The analytics centre of excellence (ACE), the new propositions team, the integrated customer communications team and the information policy and business control team. Together they focus on how to use information more effectively to deliver brand trust to customers through new propositions, ever-more relevant communications to customers, support business analysis and build out the bank’s customer focus.
The information policy and business controls team sits alongside the analysts and innovators ensuring that customer data is used appropriately. “If we are using personal information, is that what the customer might expect? When the business is developing an information-based innovation, we encourage them to take a step back and ask whether they would feel confident explaining it to their own grandmother,” she says.
“One of the first things we did when Information Business was created was to look at all our policies in order to understand if there was anything we might need to address, such as whether information the business was planning to use was ethical for them to use,” explains Good. “We also looked at our terms and conditions and the customer journey.”
“As part of this, we recognized the need to use language that is clear, transparent and accessible rather than legalistic. Getting the tone of voice right and simplifying our terms has ensured transparency with our customers, in turn allowing us develop new services with confidence, such as SmartSpend, a free service that enables Barclays Online Banking customers to get cashback and save money on goods, services and travel,” says Good.
The Data Protection Act does not cover personal information which has been correctly anonymised and cannot be resolved back so an individual is identifiable. However, ensuring that customers fully understand how this has been done and what protection is in place to prevent their personal information from being seized on by external parties is an ongoing task for the team.
“What has really helped was setting out our five key analytics principles,” she notes. The first is to make sure the data being used is data which the user has authority to use. Second, apply data minimisation and don’t make copies unnecessarily. Third, consider anonymisation and pseudonymisation unless there is a specific need for items of personal data, so techniques like age bands are applied, rather than using actual dates of birth. Fourth, ensure aggregated data cannot be disaggregated to identify the individual. Fifth, apply the ICO’s Motivated Intruder Test concept to make sure nobody can get hold of personal data or identify an individual even if they are really determined.
Analysts within ACE have welcomed the principles as clear, practical explanations of what data governance means for them during the creation of reports and insights, as well as other tasks like the extraction, transfer and loading of data from one system to another. By ensuring data meets these standards, the bank has been able to develop market-first services based around information, such as Local Insights, a service launched in 2013 which used the anonymised data to give MPs insights into their constituencies. It was so well received that it was opened up to the public. More recently, Barclays launched SmartBusiness, a product for small and medium-sized enterprise customers that allows them to look at their own data and compare themselves to similar businesses in their area or nationally.
Developing data-driven and technology-based services for customers constantly gives rise to issues about the maintenance and accuracy of that data. For that reason, the Customer Data Oversight Forum - led by Barton - was created. It provides oversight of any activities affecting the quality of customer contact data and has become the go-to place for any function needing guidance on a proposal. “We identified who needed to be around the table and decided if we built it, they would come. It has become a self-fulfilling prophesy,” says Barton.
“We have got the right people around the table to come and tell us what they want to do and we’ll work with them to find out what’s possible. It started with a focus on UK retail banking, but word of mouth has spread and other divisions are now joining in,” he says. “When people send in a submission, they know there are things everybody will ask, so they tell us what the answers are at the outset. We want to help the business and help them to know those answers.”
Creating the Forum has given the whole group a focal point for new data quality-centered activities. Previously, building a proposition that relied on the use of personal information would have required the line of business to get separate meetings with IT, legal and compliance, risk and customer experience. Now, a submission to the Forum gets looked at by all of those functions in one round.
That not only ensures a clear customer focus from the outset, it also enables more innovation and business opportunities to be exploited. In one example, support by the forum to move customer data between systems - including overcoming last-minute technical hitches - resulted in 30,000 extra customers receiving information about a new product they qualified for. Barton won the Data Governance and Privacy Professional award, sponsored by DQM GRC, for his leadership of the Forum.
There is still much more for Barclays to do - as Good points out, compliance is a journey, not a destination. In addition to the General Data Protection Regulation, a raft of other legislation and industry guidance is affecting the banking sector, such as electronic identity verification (eIDV), the Payment Services Directive, the Open Banking initiative, and the Competition and Markets Authority. Barclays has also become one of the approved providers to the GOV.UK Verify programme, providing accredited identities for consumers wishing to use selected government digital services.
Embedding data governance through clear, practical guidelines and business-as-usual programmes is ensuring Barclays can take advantage of such new opportunities while maintaining customer focus, brand trust and commercial benefits. As Good points out: “We have done so much, but there is so much yet to do. That is the beauty of this and what makes it hugely exciting because we have an opportunity to have an impact.”