There is an appreciation of informed consent being a necessary (even when insufficient and somewhat imperfect) tool for personal data protection. Ideally, informed consent would make customers aware of how various service providers would use their personal data. This active information can help customers hold the providers to account and seek justice in case of deviation.
Building on this intuition, the Reserve Bank of India set out the Guidelines on Digital Lending (2022) and their Master Directions on NBFC-Account Aggregators (AAs) (2016). Both these policies require that consent obtained by these financial service providers (FSPs) be explicit, prior, and revokable.
Yet, literature on customers’ experience of consent suggests that customers do not read through consent screens. Even when a small minority do, they find them incomprehensible. This is further accentuated by the ‘shrink-wrap’ nature of consent screens as they exist today. There is no scope to seek clarifications or reject some terms and conditions in part. This difficult-to-read and non-negotiable nature of consent is often cited as the reason for low customer engagement with consent screens.
However, as discussed in the previous blogs in this series, behavioural factors play an equally important part in active disengagement of the customers with consent screens. This blog links to a behavioural study conducted jointly by Dvara Research and Final Mile to uncover mental models that may nudge customers to disengage with consent screens. The study has been conducted in the context of a lending use-case via the Account Aggregator system. The attached deck sets out the method and key findings of the study. The findings are also summarized below for a quick reference:
While applying for a loan via an Account Aggregator, customers may disengage and passively comply with consent for the following reasons:
Cite this blog:
APA
Final Mile, Dvara Reasearch (2023). How mental models interplay with consent: Unpacking challenges to informed consent. Retrieved from Dvara Research.
MLA
Dvara Research and Final Mile. “How mental models interplay with consent: Unpacking challenges to informed consent.” 2023. Dvara Research.
Chicago
Dvara Research and Final Mile. 2023. “How mental models interplay with consent: Unpacking challenges to informed consent.” Dvara Research.
