Conducting research for a bank
 Are there additional rules that must be followed when conducting research for a bank?
 Nearly all banks in the UK subscribe to the Banking Code and the Business Banking Code. These Codes set down how banks will treat their customers, respond to complaints and also the purposes for which customer data will be used. Of particular relevance to this discussion is rule 11.1, common to both Codes:
11.1 We will treat all your personal information as private and confidential (even when you are no longer a customer).We will not reveal your name and address or details about your accounts to anyone, including other companies in our group, other than in the following four exceptional cases when we are allowed to do this by law.
- If we have to give the information by law.
- If there is a duty to the public to reveal the information.
- If our interests mean we must give the information (for example, to prevent fraud). However, we will not use this as a reason for giving information about you or your accounts (including your name and address) to anyone else, including other companies in our group for marketing purposes.
- If you ask us to reveal the information, or if we have your permission.
This means that as banks that adhere to this Code have made a commitment to their customers not to pass their data to anyone else for any other purpose. Bank records are therefore different from other client databases commonly used for research.
Do researchers have to be treated as bank employees to conduct research with customers?
MRS is aware that some banks enter into quite complex legal arrangements to internalise the research process, so that customer data is not transferred outside of the bank.
When establishing a relationship with a customer most banks do not obtain the necessary consent from their customers to enable them to provide a research organisation with details of their customers. When intending to conduct a market research project some banks will ask a customer for their permission for a research organisation to make contact. In this case any data collected by the research organisation is confidential as between the customer and the research organisation unless specific consent is obtained to pass information back to the bank.
Where permission has not been obtained from customers, a bank will often employ a research organisation as its “agents” to make contact with customers. In this case all data belongs to the bank and cannot be removed or controlled by the research organisation.
Care must always be taken with regard to data gathered as to who owns it and controls it and the customer must always be clear as to who is controlling the data.
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