A year on from publishing ‘The FCA Data Strategy - How we will manage and use the data we collect', we hosted our first data-focused event – ‘Working Better Together With Data’ on 25 September 2014.
We advertised the event in our August Regulation round-up and received a large number of applications from a range of stakeholders. We offered 20 places to a mixture of regulated firms, trade and consumer bodies, data providers, and regulatory partners.
The event opened with an update on the progress made in the past 12 months of implementing our data strategy. We then asked participants to work with us on two key themes - availability and use of data - and to give us their ideas and feedback, to shape our proposed next steps.
Availability of data
The following points we raised:
- many said they buy data and information from third parties to inform the choices and decisions they make. As the FCA does not want to increase the burden on regulated firms through its data requests, it was widely agreed that the FCA should get data which is in the public domain through third-party data providers. Some felt that third-party data providers could act as a ‘bridge’ or ‘pipeline’ of data to the regulator. This included providing the view of the consumer
- a number raised the need to ensure quality of data from third-party providers. Discussions focused on ensuring clarity of understanding as to the processes and checks undertaken on data, whilst still ensuring the validity from source remains. Participants felt that quality of data is a joint responsibility, between the collector and client. There is a need for standardised terminology on data in both firms and the regulator, to drive consistent understanding
- the FCA should consider appropriate commercial arrangements to ensure that any agreements to purchase data are fair to all parties and do not impact negatively on competition. There is a need for regular reviews of any commercial arrangements
- participants discussed the merits of firms supplying data directly to the FCA, including the knowledge of the data which firms hold and control this enables. There were differing opinions on where data should be sourced from to inform a baseline and that which is required for deep dives
Use of data
The following points were raised:
- whether the data sourced from third parties should be used by the regulator as intelligence or as evidence. It was largely agreed that the data should be used to inform the FCA’s radar, to highlight areas for investigation, rather than being used solely as a basis for action
- there are many benefits of third parties providing data to FCA, including leveraging the experience of providers and the availability of packaged data services providing cost effective indicators across a broad range of data
- the Ssecurity, quality and interpretation of data provided by third party data were raised, and would require appropriate agreements between a data aggregator and customer
- the regulator needs to state a purpose for data collections and be clear about its intended use, so the context of data is recognised and retained, especially when data is obtained from a third party. Currently, context is set for data collections via the FCA’s GABRIEL reporting system. A system of clearly defining context would be required for any data obtained through other routes
- transparency was a key theme. Discussions included clarity on use, accuracy, purpose and ownership of data, and that these are all factors the regulator should be clear on with third-party data providers and firms. Participants were largely supportive of the FCA publishing market-level data, and welcomed the benefits this would provide
- we are working through all of the input and feedback we received and will use it all to inform our next steps in implementing our data strategy
- an overarching theme from the event was the opportunities provided by future collaboration between the regulator and key stakeholders. We intend to maximise these via future events and engagements, and in the short term plan to hold future technology and consumer focused events
- we will publish a data strategy note and video in October 2014, giving a broader update on our progress and next steps
Feedback on the engagement approach
As part of a commitment to continuous improvement, we sought feedback from all roundtable participants on the approach taken to the sessions and the value gained from their attendance. Feedback was overwhelmingly positive
- 86% of respondents stating that they would be interested in working with the FCA on data related activities
- 93% rating the event delivery as ‘excellent’ or ‘very good’
The written feedback on the sessions from participants and the recommendations made for improvements will be taken into account when we are planning our future ongoing engagements.
We would like to thank the participants for giving up their time to attend the event.