22seven is very much a data company, and we’ve done a lot of soul-searching on what that means. This is our data ethics manifesto.
We all leave data trails behind us in our digital lives.
What you read and buy, where you click and when you do it, even where your eyes are looking – these things can be tracked and analysed. Data scientists are discovering new techniques daily to pull insights out of all that data (usually to sell you more stuff). The intimacy and accuracy of the things that can be predicted is unbelievable. Machine learning algorithms chew through huge datasets, finding patterns and making predictions that the greatest human minds could never achieve. At 22seven we do a lot of this cool stuff, and that’s why we have to have strict rules.
Buying and selling data.
No bit of data from your life is neutral. Whether it’s where you shop or who you bank with or how much you spend at restaurants – all these little pieces add up to a very intimate and detailed portrait of your life, so it would be a bit dishonest to pretend that individually they don’t matter. These are tiles in a mosaic, and since they can collectively make up a detailed picture, individually they must be treated as sensitive and confidential. Because the data is so powerful, it’s very valuable. Because it’s valuable, it’s often bought and sold, often without your knowledge or benefit. We will never sell your data, nor will we buy more data about you. (The only exception is that if you are an investor with us, we do pay for data verification services, which we are obliged to do for FICA purposes).
If, in the future, we ever do want to buy or sell data about you, we will seek your explicit consent and without your consent we will do nothing. If we go out of business, or we are acquired, your data will not be sold or handed over to anyone else. If at any time you ask us to forget you, we will purge almost* every trace of your financial life from our database. Just bear in mind that once we do that we can’t get it back for you 😉
* We are obliged to still keep your name, email address, Yodlee Username, customer ID, Ticket history and Zendesk audit logs, so that we can prove we ever had you as a customer.
The REALLY personal stuff.
For a data scientist, personal details like gender and race can be fascinating, but these attributes still attract serious societal prejudice. Usually they’re also facts that people don’t get to choose. We’re interested in the choices you make, but your body is none of our business – so we won’t try to collect this information and we won’t use the information you do give us to try and work it out. However, we do think that your age matters. We don’t care about grey hairs, but we do care about things like years until retirement. A bit like having kids, getting older changes the decisions you make and the advice and information you need to make them. A young person in their first job and someone approaching retirement have very different options. If you do decide to share your age with us, it will be your choice, and we’ll use that information to tailor our suggestions to be more relevant to where you are in life. It will be an explicit request, not something buried in a lengthy Terms and Conditions document. Note that if you’re an investor with us, you did give us your ID number – but we will not use this to figure out your age without your consent. While it’s an easy thing to do, we want real permission from you, not presumed permission.
So: we won’t buy, sell or share your data, we will not collect or derive creepy personal demographic data, we will delete your data forever as soon as you ask us to, and we’ll always ask and wait for your permission before we change any of that. We are here to help our customers lead healthier, happier financial lives and all our data choices will be in direct support of that one goal.
A note for our investment customers: all the FICA details you supply will be visible to our Svens for verification, and then we will have to give those FICA details to the Financial Services Provider partner that holds your investment. We never share your personal finance planning information with that partner – we transfer only the minimum data required under South African law so that the investment partner can administer your investment legally. Because they do administer your investment, they can see any transactions in and out of it, including dividends, distributions and switches to or from other funds. We can’t prevent our partners from enriching that data themselves, but whatever they do will be governed by South African data privacy laws. Also, if you choose to close your 22seven profile, South African law obliges us to hold on to your data for at least five years – please contact our Svens if you’d like more details.