Thinking back on my recent week of teaching a banking technology class at GSBC, there was one theme that came up across numerous elements of the technologies that I was discussing. To provide a backdrop for examining the theme, consider the following scenarios: A customer clicked on an ad for a Gold Mastercard while using online banking but abandoned the session and did not complete the application. The following week while at a bank branch, a CSR asked the customer if there were any questions about the Gold Mastercard and would it possible to assist the customer in completing the application. A concierge greets each customer as they arrive in the branch and once they know who the customer is, they bring up a dashboard on a tablet that shows a complete overview of the customer. The concierge can assist the customer to where they need to go for banking services or make recommendations based on their profile of accounts, including asking if they wanted to complete the unfinished Gold Mastercard application. The same concierge referenced above knows who the customer is before they ever walked into the branch because the bank has a beacon in the front of the bank that picked up the cell number of the customer as he or she was getting out of the car. As soon as the customer comes inside, the concierge greets the customer by name. A customer of a bank is at a local car lot looking a purchasing a new vehicle. While at the lot, they get a text on their phone that indicates that the bank has low interest car loans and would love to arrange for financing for any new car they would like to purchase. The text is generated because the bank has a Geofence around every car lot in their service so they can detect any cell phones with location services turned on going into those specifically defined areas. OK, enough scenarios (although I could go on, and on and on…) Here is my question, how many of the 4 scenarios I detailed above would you consider to be “creepy”? Not sure how I define creepy? Glad you asked. Creepy is a highly non-technical term that means that an entity such as your institution has harvested data and subsequently used that data in a manner that would creep out a customer. On one hand, it’s a bit like former Supreme Court justice, Potter Stewart, who when asked to define obscenity declared, “I know it when I see it.” We can definitely say something is creepy when we experience it. On the other hand, what we might think as clearly creepy might not be so creepy after all to our customers. Let me elaborate. As banks, we have highly structured data. It’s not “Big Data” like all of the text in tweets in a 24 hour period, but it is important data that can be evaluated for purposes of making the next best product recommendations, determining levels of risk, appropriate credit limits among other uses. I find that most banks are only mining and using data in the most rudimentary way. Perhaps this minimal use of data is a direct result of the bank wanting to stay clear of the “Creepy Line” even if that is never clearly defined. The fact is that we have the ability to get very granular with how we can use the data we have on customers to provide a very high level of personalized service. But very few banks do, and it’s likely that this is because of the fear that the customer would be off put if we were using their personal data in this fashion. But this limitation requires the customer to be actually offended by our use of their data. What if they weren’t offended at all? Try this experiment. Go to Google and search for something you have never searched for before; for example Luggage. Click on any link for luggage and then go to any social media site such as Facebook, Instagram or YouTube and use those as you would. Do you see any links or ads for Tumi, Brigs and Reilly or Samsonite? Probably so. Now that I have alerted you to this fact, you will see these ads turn up even more as you search, surf and do social activities online. Your IP address and the cookies that are set when you access websites follow you around the web and enable the ads that seem to magically pop up on a subject that was the target of a recent search. Interestingly, Google has shut off selling ads based on browsing history as of March of 2021. Nevertheless, the fact that our online activity is being tracked and that other entities can know where we have been and what we were doing is no longer a novelty to consumers. I find that most people are not upset that this occurs unless the information is used in a salesy, pushy-type manner to overtly sell. My point is to help bankers understand that it is possible that we are too conservative to stay so far away from the “Creepy Line” when in fact, what we would do with that data is likely to be paternalistically beneficial for our customers. We have their best interest at heart and genuinely want to make sure that they know we can provide a high level of service and ensure that they have access to all relevant information prior to making a decision on any financial product or service. Let me be clear, I am not suggesting that we allow any non-public data to be distributed outside our organization under any circumstances. Our customer’s private data had better stay private. But I am suggesting that the customer data we have can be mined appropriately and used in an altruistic manner, without our being creepy. Perhaps the main difference in a customer taking something as creepy has as much to do with how we communicate regarding the scenario in question. If a concierge says, “Mr. Peterson, I see you were online at 10:15 Wednesday night and clicked on our Gold Mastercard application…” well, that sounds pretty creepy right away. What if instead, the concierge said, “Mr. Peterson, many of the customers with a similar profile to yours have found our Gold Mastercard a useful financial service. Is that something you might be interested in discussing with an associate today?” I would think that while the fact that customer clicked on an ad for a credit card was the genesis, the second communication has a much lower “creepy” quotient. Agree? We can apply the same communication method to all of the examples I used above and many other uses of data that we have at our disposal. The key question we have to ask is NOT, should we mine this customer data, but instead, what is the desired outcome for which this data mining is to occur? Examine the outcome, is that something that paternalistically is in the best interest of our customers? If so, then come up with the narrative around which you would communicate with customers should you elect to pursue that scenario. You should be able to look at how you would message to a customer about the scenario and get a solid feel for a) not creepy, b) could be creepy but we are likely erring on the side of being too conservative or c) whoa, definitely creepy. One other point, most of what we think of as creepy applies to older customers, particularly baby boomers or super seniors. If you were focused exclusively on the prospects you will need to add as customers over the next 8 years, then we are talking about young millennials and Gen Z’s. These are the very generations who delight in sharing every aspect of their lives online and who associate payments with emojis on Venmo for all to see. There is very little that you could do in mining data that they would consider creepy at all. In fact, there is an expectation that you would be using their data to provide a highly personalized service and might think you’re too old school if you didn’t effectively use their data in this way. This issue of the proper use of customer data is far reaching. Here is another example: It bugs me when vendors where I have an account relationship offer me things that I have already purchased. It makes me think that they are not paying attention to my account relationship at all. Take the customer referenced above that clicked on the Gold Mastercard banner ad. Suppose that customer already has your Gold Mastercard, why are they even seeing that ad? This and other examples like it show that the appropriate use of data should be an element that we discuss at the senior management level and develop a strategic plan for data mining that adheres to all banking rules and regulations while maximizing our ability to target services or personalize the customer experience. Clearly, we need to not do anything that our customers would consider to be creepy. But we must also accept that our customers, young and old, are experiencing their data being used for marketing and related purposes across nearly every type of organization with which they do business. Figuring out exactly where we can appropriately and paternalistically mine the data we have to better serve our customers is an activity that is certainly worth pursuing. Do you have a question or story related to the use of customer data? Share it with me at email@example.com. By the way, if you did have a beacon that picked up my phone number before I walked into the branch and as soon as I came through the door, I heard my personal walk in music (like a baseball pitcher coming out of the bullpen), perhaps The Boys are Back in Town by The Bus Boys, that would not be creepy. That would be so cool.