Data aggregation companies have unwittingly solved the age-old philosophic puzzle of human identity. In answer to the deep metaphysical puzzle of "Who am I, really?" the data aggregators now answer - you are the aggregate sum of your transactions in the marketplace. By aggregating all these transactions out of individual events, each one of which in itself is not particularly significant, the data aggregators have actually constructed an identity for you and me. The unintended consequences of the data warehousing technology occur when this identity escapes you or me because it is misappropriated (i.e., stolen).
This points to a deep policy issue. The data aggregation definition of identity is basically accurate but incomplete. My identity is the aggregation of individual transactions plus the integrity that makes me accountable for those interactions. An individual can begin something new (e.g., a series of additional transactions). The glue holding together my identity is my integrity, independent of any particular transaction.
The ability to operate in a free market economy depends, in so many ways, on the free flow of information between economic agents - individuals or firms pricing, buying and selling goods and services. It is a matter of public record that I have used my payment card at various stores and that I paid on time, late or not at all. This enables others to decide if they want to do business with me and also what risks and opportunities that presents. By aggregating a series of transactions over time, data aggregators have arguably added value. They have created a model of an individual consumer's buying behavior in the market.
However, because data aggregators have created a model of the individual consumer, they have arguably also created the responsibility to treat that model with the same care that would be given the individual. The data aggregators must be accountable for and promptly correct errors. Consumers should also have access, in a proactive way, to the information that is aggregated about them.
Recommendations for data aggregators include: anonymizing sensitive personal data (e.g., Social Security numbers and account identifiers) in reports provided to subscribers. Treat loss of data as a data quality issue. Data that is not secure lacks quality. Take steps to secure the data against unwarranted use. If the problem is a faulty business process - a breakdown in authentication as to who is authorized to receive the consumer report - then treat the matter as a business quality issue. Strong encryption or anonymization of the data will not solve the problem if the report is voluntarily given to a hacker who says he is a client but is not. Establish a case manager or ombudsman to troubleshoot consumer complaints and provide assistance to hapless consumers with whom you may not have a direct relationship (because someone else bought your data about them). Be accountable for the accuracy of the data you have colleted within the policy framework of "to err is human, but not to fix your errors is inexcusable."
Because there is no single public office where a consumer can go to recover her or his damaged identity, recommendations for consumers imply more work in being vigilant in monitoring and shredding junk mail which may contain sensitive identifiers. Do not respond to unsolicited e-mails from alleged financial services firms. When in doubt, pick up the phone and talk to a human. Do use the Web (e.g., Google) to gather contact information for data aggregators, credit bureaus and your U.S. Senators and Congressional representatives. If you believe you have been a victim of identity theft, aggressively request to see all credit and account files, ask that a freeze be put on your file, dispute and repudiate inaccurate statements and charges by registered mail and keep a copy. Unfortunately, this may have to be done repeatedly.
"Whose identity is it?" is a rhetorical question. My identity belongs to me. I cannot opt out of it anymore than I can opt out of participating in the pubic life of the marketplace. However, I can exercise the right - in some cases a still emerging right - to see the details of my identity and correct any inaccuracies. This will change the business model in significant ways; however, that too is one of the unintended consequences of the technology.
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