Fair Use Initiatives in the AA Ecosystem: A Report Card
In a recent session titled “Fair Use Initiatives in the AA Ecosystem: A Report Card,” Ms. Shalini Gupta (Head of Strategy & Policy, Sahamati) and Ms. Geethashree Srikantha (Senior Lead-Operations, Sahamati) presented an in-depth analysis of the progress achieved through the ecosystem’s participatory governance mechanism. The session provided valuable insights into the initiatives designed to promote fair use within the account aggregator (AA) framework, emphasizing user-centric approaches in line with the Digital Personal Data Protection (DPDP) Act.
Overview of Participatory Governance and Fair Use Framework
The speakers highlighted the alignment of the account aggregator framework with DPDP principles such as lawfulness, fairness, and transparency. They introduced the concept of participatory governance, where stakeholder feedback—from customers to industry representatives—is instrumental in shaping guidelines and best practices. This collaborative process is seen as a cornerstone for governance in the expansive financial sector, which encompasses thousands of institutions.
The development of a fair use framework is central to these initiatives, targeting six key areas:
- Onboarding checks for regulated entities
- Customer experience guidelines
- Fair data usage limitations
- User interface best practices
- Certification of service level agreements
- Maintenance of data quality
The upcoming year’s focus will be on leveraging technology-driven compliance mechanisms, moving beyond manual checks to ensure adherence to fair use policies across the ecosystem.
The Fair Use Template Library: Standardizing Consent Parameters
A significant milestone in these initiatives is the creation of the Fause template library, developed in collaboration with councils comprising members from diverse organizations. This library addresses over 20 identified use cases, establishing standardized consent attributes for scenarios such as loan monitoring and compliance reporting for insider trading. Each use case specifies purpose codes and limits on data usage frequency, ensuring clarity and uniformity for financial institutions.
Previously, inconsistencies in data pulling frequencies posed challenges, but the new templates provide clear guidelines within regulatory frameworks. Additionally, the councils have refined user interfaces to align with principles of informed and explicit consent. Recent updates to consent screens used by financial institutions exemplify these efforts.
Enhancing Informed Consent Protocols
- The session also detailed improvements to informed consent protocols aimed at financial inclusion. Key enhancements include:
- Expanding consent screens to comply with regulatory requirements, ensuring essential information is displayed.
- Allowing users to selectively agree to specific consents instead of accepting multiple conditions at once.
- Clarifying the roles and use cases of financial institutions (FIUs) onboarding to the AA framework.
- To monitor compliance with consent guidelines, an automated system has been implemented. This system proactively assesses alignment with established policies, detecting and addressing deviations. The speakers emphasized the importance of continuous support and consultation with FIUs to ensure seamless integration and adherence to fair use standards.
The Road Ahead
Ms. Gupta and Ms. Srikantha underscored the essential role of participatory governance in maintaining trust and transparency within the AA ecosystem. Through initiatives like the Fause template library and enhanced informed consent protocols, the framework continues to evolve,prioritizing user-centricity and compliance. With resources and continuous support available for financial institutions, the AA ecosystem is poised to set new benchmarks in fair data usage, fostering greater trust and inclusivity in India’s financial landscape. The complete session recording can be found here.
