I attended a meeting of the midata Transmission working group this week, which reviewed a set of scenarios based on those described in my previous post on this topic. I've updated my legal presentation by way of an overall summary, and will embed it below shortly. The working group scenarios are likely to go into a bit more detail and involve additional sub-scenarios. I assume they will be available once they have been reviewed by all the working groups and are considered in final form - possibly as part of a final report.
In essence, our discussion this week focused on:
- clarifying the likely use-cases and consumer/small business benefit: the first few scenarios reflect how midata currently flows (e.g. release of current account data via online banking) which we agree is not terribly consumer friendly. The later scenarios reflect a more likely outcome, as new analytical and 'dynamic switching' services arise, for example, or as consumers begin to negotiate specific products or pricing (whether alone or in collaboration with others); and
- differentiating the various types of services that may be offered by new intermediaries (previously called 'personal information managers'):
- Midata Store: this service would only involve the provider acting as a reasonably passive repository of midata on the Customer's behalf, (e.g. merely holding it, or displaying and/or transmitting it without any alteration) could be called, say, a "Midata Store". It was also considered necessary to distinguish between a Midata Store that only receives midata from the Customer, and one that receives midata directly from a Current Supplier via a direct interface ("Linked Midata Store");
- Midata Service Provider: this type of service would involves the receipt of midata on the Customer's behalf for the purpose of analysis, combining that data with other data and/or producing some kind of reliable result for the purpose of negotiating with Current Supplier or Third Party Supplier would involve processing on a greater scale. This would clearly involve more technological (as well as contractual and co-regulatory) safeguards.
It was considered that Midata Stores and Midata Service Providers are likely to evolve their own specific technology/transmission standards and self-regulatory codes quite quickly, in addition to any trnsmission guidelines etc produced by the Midata programme. However, it would be difficult to mandate the creation of a specific trade body or related code at this point.
The next meeting I am due to attend is a meeting of the legal and regulatory working group at the end of this month.