Consent is a critical part of communication between users and providers of Digital Financial Services (DFS). However, the consent and notice model for DFS has many deficiencies, especially for constrained users, i.e., users with limited literacy and first-time smartphone users. This project sets out specific recommendations on how providers such as Account Aggregators can make consent customer friendly. These recommendations emerge from a qualitative primary study which examines why customers currently do not engage meaningfully with consent artefacts and how a behaviourally informed design could improve understanding and engagement
We find that among low-income borrowers, the borrowing journey is shaped by financial stress, time pressure and fear of being denied formal credit, which in turn influences consent decisions. This macro-context shapes individuals’ micro-decision of consent. Furthermore, the shrink-wrap design of consent artefacts offers little scope for negotiation or challenge, affording customers little real choice, leading customers to passively comply.
These findings have been translated into actionable recommendations for redesigning consent artefacts to ease the customer’s loan application journey. They aim to make the journey easier and empower customers by acquainting them with the concepts of consent, personal data, explaining to them the role of their persona data in the lenders’ decision, reducing the barriers to engagement by using local languages, visual cues live chats and finally offering an accessible redress and enquiry mechanism. The recommendations are available here, the findings from the behavioural study are available here, and the first principles research on the need for informed consent in financial services is available here.
