Building a Code of Conduct for Greater Inclusion in Identity and Financial Systems

The Human Impact of Identity Exclusion in Financial Services

 

We commissioned Caribou Digital to conduct research into the Human Impact of Identity Exclusion. As part of that work, several people who have experienced  ID exclusion were interviewed in the UK and Ghana. Va-Bene is a transwoman—or as she calls herself, a transvatar—based in Kumasi, Ghana. She faces challenges every time she goes to a physical bank branch. Her IDs (and particularly the photos on them) don’t reflect who she is now. “If I have to withdraw money with my ATM card, that is fine. But any other thing I will do directly in the bank. Believe me, either we are going to fight in the bank or I’m just going to be delayed for several hours without any money.” Being denied access to her own money not only has a direct financial impact on Va-Bene. It also has an emotional impact: “it is very frustrating when I am excluded. Very, very frustrating. Very depressing.”

 

[See Va-Bene’s video here]

 

Va-Bene is the first of several participants we spoke to about the impact of being excluded from financial services due to poor or complex ID systems. We asked Caribou Digital to conduct research in the UK and Ghana to explore emerging themes from these two, very different, contexts. They spoke to a range of participants who are or who have felt excluded from financial systems for different reasons. These powerful stories will be shared with the teams responsible for designing financial services and products, who aim to learn how they can design more inclusive products. 

 

This research is the first step towards building a comprehensive set of guiding principles and framework for inclusive ID-product development. Using a human-centred design (HCD) approach, we intend to build a Code of Conduct to explore how users in the UK and Ghana (as representative of a developed and developing economy) deal with ID challenges, including identifying work-arounds users have developed, and recommendations for product designers and developers to build into ID systems to minimise disruption for users without compromising security and trustworthiness. 

 

Our Identity Code of Conduct will establish a set of guiding principles around inclusion, building on the broader Digital ID Principles. It will offer a practical set of tools to address inclusion at every stage of identification. 

 

Nowhere is this more necessary than in financial services, where ID is needed to protect users (e.g., from financial crime), as well as provide access to specific products. Service providers need to know who users are, but how does that process happen, why, and when does it become problematic?

 

“Know Your Customer” and existing challenges of exclusion

 

In her book In Pursuit of Proof, Tarangini Sriraraman documents how “identification” began as a need to recognise individuals for governance, but has become a process heavily shaped by social norms. Why is gender an important characteristic for identification? Who decides how that is categorised (male/female)? What happens when gender goes beyond binary, as in Va-Bene’s case?

 

“Know Your Customer” (KYC) is a legal requirement to comply with anti-money laundering regulations (AML) in most countries. Verification requirements to access financial services often include database checks, identity document verification, and, increasingly, biometric checks. For proof of address, utility bills or bank statements can often serve as acceptable documentation. By verifying a customer’s identity and intentions when they open an account, and then understanding transaction patterns, financial institutions can more accurately pinpoint potential account takeover or other suspicious activities.


However, many people get stuck when trying to prove who they are (like Va-Bene) or where they live. Obtaining an ID can be a time-consuming and expensive process, made more challenging for those who are female, from an ethnic or racial minority background, live in a rural area or with a disability, or are refugees or migrants. Youth, too, are emerging as a demographic facing barriers to ID. Often these issues include not having a proof of address (being without a fixed address, having recently arrived in the country, or for other reasons) or not being able to easily prove who one is (not having foundational ID documentation). These challenges can become even harder to address without knowledge of where to go or what to do next.

 

Interview with Payal, a recently arrived migrant in northwest London, UK, who faced challenges opening a bank account without proof of address.

 

Our Identity Code of Conduct: A guide for financial service providers

 

At Women in Identity we believe identity solutions should be inclusive, built for all, by all. But we also believe this does not happen by chance. 

 

The aim of our initial research and videos is to work towards this Code of Conduct: a practical guide for product designers to gain deeper empathy for the challenges experienced at the user end of the ID lifecycle and the knowledge to take these challenges into account when designing products. 

 

Other sectors already take this approach to product development. The pharmaceutical industry, for instance, has an ongoing Code of Practice based on principles of care, fairness, honesty, and respect that impact agreed standards of product development (e.g., clear and transparent information on packaging). 

 

We believe we can learn from other industries and create an Identity Code of Conduct which ensures inclusion is built into identity product design, thus making these products better for the organisations that rely on them and for the people that use them. 
 

We look forward to you joining us on this journey and welcome feedback and suggestions. Please reach out to us on @WomenInID on Twitter or @WomenInIdentity on LinkedIn!

 

Read more about this project at ID Code of Conduct and follow us at @womeninID @WomenInIdentity @CaribouDigital #DiversityByDesign #ForAllByAll #IDCodeofConduct #IdentityExclusion 

 


 December 23, 2021