Thanks for bringing this to our attention.
This is squarely my area (by way of Descant). I'm a bit crunched at the moment so not able to provide a thorough analysis relative to VRM but if you think back to everything I've said in past VRM days as well as on these threads, it claims to provide a data facilitator platform congruent with all that working code I've been sitting on for much too long!
First, thoughts on the article. Then below that, a reference to the Equifax announcement yesterday.
A couple characteristics that fit the VRM way, and that are at least implied in the article:
- It revisits the flows of data for credit analysis "through the eyes of" the subjects of the data. It's always important to question the extent of this agency when it's banks rolling out the solution but the spirit of subject-driven data flows seems to be present.
- It addresses a gap in data pipeline management on a narrower basis than will be necessary to scale and than we offer via Descant. See the specific reference to an India-specific requirement that financial data be reported in a standard, machine-readable format. More on this below.
- It suggests consents will be easier to understand because data subjects can choose to share portions of data. This is a very big challenge and one we've largely solved by enabling UI/UX that spreads out consents across touchpoints. Easier to provide for context-based consent in that manner. It's not clear that India is thinking in these terms. Indeed the intent seems to be that fintech startups will build apps on top of the platform. Unless there are constraints on the spirit and intent of such apps, they could be heading back to opacity with little opportunity to pull it back. Also, more on this below.
Data pipeline management:
Of all the big data challenges addressed over the past decade, pipeline management has only recently popped up as a significant area. I have only seen developments (and patent filings) for pipelines within enterprises. The essence is that applying transformation, processing, and governance to data while in motion streamlines its path to insights. As the category implies, it's a more fluid approach to data management for sure as compared to the old ETL model and arguably data lakes.
A facilitator platform that replaces credit bureaus will need to management multiple pipelines, each potentially presenting different levels of privacy-sensitivity and latency concerns. The solution announced by this article is a reasonable start but not as extensive as would be needed to truly replace an Equifax. I didn't see a plan to, say, open source the system so extensions for additional data pipelines could emerge.
Note that this data challenge is not obviously about privacy but it is critical if the goal is to replace intermediated data solutions. This is a good a place as any to include a link to an opinion in yesterday's NYT about the indictment of Chinese hackers for the Equifax breach. Author makes the point that the whole model underlying Equifax and data brokers is the problem. And that is a more complicated data pipeline problem than consents.
Context-based consent etc:
Just adding a short note that I've been studying recent efforts to add language to open source licenses that encompasses privacy, data rights, and/or human dignity. As far as I can see, this is all new territory. In the "humanitarian license," the author combines language from the MIT open source license with language out of the UN's declaration of human rights. So far OSI seems poised to reject it as a "blessed" open source license. NYU School of Law also has some similar projects underway.
I care about this because when I think about open sourcing the data-sharing platform of Descant, I worry much more about extensions in conflict with the ethos of people in charge of their own data than specific uses of the source code. This goes to my concern that opening up for fintech startups would be problematic if there's no way to police data usage.
Again, this is all off the top of my head. The title is correct that it is better than the US but then we are a dark and surveilled country headed for very bad days unless we can get a grip.
Let me know of any questions/afterthoughts.
Thanks again Doc!!
LaVonne
503-720-0690