DSIT's consultation on Smart Data opportunities in digital markets - Which? response

Which? welcomes the opportunity to respond to the Department for Science, Innovation and Technology (DSIT) call for evidence on smart data opportunities in digital markets. 

Our research shows that consumers often feel powerless to challenge or negotiate with organisations that hold their data, constrained both by limited knowledge of data practices and by their dependence on data-driven products. These challenges are compounded by competition issues. In many digital markets, a small number of dominant platforms hold vast amounts of user data, giving them a significant competitive advantage over smaller rivals. Where competition is weak, platforms have little incentive to improve the quality of their services, including mechanisms for consumers to access or share their data. Smart data schemes in digital markets should empower consumers to navigate these complex environments more successfully. 

Smart data gives consumers the ability to share their data between businesses and other organisations, to enable new uses of data in ways that benefit consumers, society, and economy. As the UK consumer champion, Which? is committed to ensuring that smart data initiatives work in consumers’ best interests. Which? proposes a model for smart data trust frameworks which is underpinned by principles of governance, protection and scalability. These aim to embed consumer control and trust from the start and create a trusted ecosystem for data-sharing within digital markets and also between digital markets and others. 

If smart data initiatives are developed in an ad hoc way, consumers risk facing inconsistent protections and fragmented experiences, with a failure in one sector affecting engagement with the whole ecosystem. Without this cross-sector join-up, there is a risk digital markets will operate in isolation, which introduces risk of harm and detriment to consumers.   Our trust framework seeks to address this by providing a set of minimum and consistent cross-sector requirements on participating organisations, which protect consumers from harm and foster trust and confidence.