Much has been written about the GDPR – the fines, the increased enforcement, individual rights and greater compliance obligations. While the changes are here to stay, and are being enhanced in the UK by the proposed Data Protection Bill in the Queen’s Speech, Shoosmiths’ Stephen Dawson and JP Buckley suggest it is both a compliance issue and an opportunity.
W hile there are very real challenges to compliance, the steps taken to reach compliance should be seized as an opportunity to enhance how you collect data, what you can (legally) use it for and how else you can then use it.
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There are constraints and steps that need to be taken to make this happen, but showing the very clear benefits of such an approach will encourage teams to engage more.
There are grey areas – both in the drafting of the GDPR and in terms of the guidance which is to be issued to interpret it – but there are steps organisations can do take optimise their data collection and use.
Here is an example from another sector, and some suggestions for the motor trade: I undertook a data protection compliance review for an airline. Its in-flight systems had Wi-Fi, but it was the third-party provider which captured (and kept) the travellers’ data.
I suggested as part of my data optimisation review that this was a great source of additional data for the airline – as only a proportion of flyers book direct with airlines – and by using the loyalty club details a better profile of travel could be built up, both for members and non-members.
This went live recently, and will give free access to loyalty members and enhanced datasets for the profiling envisaged in the loyalty club terms.
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By GlobalDataSimilar potential examples for the motor finance industry are numerous. And any ideas are likely to involve collecting more personal data from customers, collecting the data more frequently and using the data that you do collect more fully.
Personal Data
Personal data in our sector is going to become indivisible from the use of car technology.
From a finance point of view, personal data has historically been based on the information provided at the point of finance application, with consents as to marketing captured once only. And that has been the end of the story, despite the customer having anything up to a four- or five-year relationship with a finance company.
As we move rapidly more towards the connected car and autonomous vehicles, current attitudes to personal data will need to evolve and relationships between manufacturers and importers will need to become more joined up with finance companies. Put as a simple question: are you ready to share more?
Data connected to use of a vehicle, and wireless services will become relevant. Data connected to driving style and insurance is of course already now in mainstream use. GPS tracking and driving style have long been used in the telematics market in the HGV sector, and they are now creeping in with some sectors of the motor finance market too.
If I were to make any specific recommendation today, it would be to work out where data is going to come from, who has an interest in that data – it may be you, it may be a third party – and decide how you are going to capture that data, together with consent as to its use.
Online distance sales channels are revolutionising car sales in certain sectors and the ‘click-to-buy’ revolution is firmly established now. This makes it much easier to inform customers as to how you will use data, to gain consent and to regularly keep in touch with marketing. and suggestions as to alternative or add-on products.
Be proactive, and think about using data much more during the lifecycle of a customer journey. Starting with ‘window shoppers’ online, test drives, at the point of finance applications, on an ongoing basis and at the end of the finance period – these are all key milestones in a customer journey and a well-informed finance house should be capitalising on these opportunities. Remember, it is not just all about marketing – it is about optimising how you interpret making the most of ‘use’ data.
And finally, a word of caution: The GDPR does also introduce a need for some homework for your own businesses in respect of personal data that you hold in respect of employees and other third parties. Time to do some housework, which often takes the form of a data protection audit.
Embrace and prepare for change in this sector. It is coming sooner than you think.
