COFACE-Families Europe has sent a contribution to the HLEG on AI, commenting on the draft paper circulated ahead of a workshop organized on the financial services ecosystem (15th of February 2019).
The draft paper focused on the issue of financial service providers’ facilitated access to various types of consumer data through the use of artificial intelligence. COFACE Families-Europe has raised several points of concern.
While the paper discusses the issue of access to consumer data, at no point are other issues such as data relevance or data minimization mentioned or discussed (in line with the General Data Protection Regulation – GDPR). Purpose limitation, which restricts the use of data based on a specific objective, should also be mentioned. Other parts of the GDPR specifically regulate how and for what purposes data can be used.
In this regard, the requirements pertaining to creditworthiness checks in the EU mortgage credit directive, and perhaps the EU consumer credit directive after revision, do not specify which data is needed to carry out this process. Depending on the situation of the country, banks proceed differently. However, despite this difference in the data used, there is no proven benefit in terms of lower default rates or lower risks. More data seems to simply lead to more individualized risk based pricing, consumer segmentation, with the poor/vulnerable paying the price (less socialization of risk).
Before thinking about facilitated access to consumer data, it is essential to clarify which data is relevant for the various financial products sold by banks, otherwise it will lead to discrimination on a wide scale in access to financial services.
COFACE-Families Europe will continue to follow the work of the HLEG on AI to ensure that the interests of families are taken into account.
For more information, contact Martin Schmalzried: firstname.lastname@example.org
Or visit the official website of the HLEG on AI: https://ec.europa.eu/digital-single-market/en/high-level-expert-group-artificial-intelligence