Shared Customer Data vs Data Ownership

Establish customer-controlled consent management with clear custodianship policies to satisfy GDPR data-ownership and accountability obligations.

CyberTRIZ analysis · Banking contradiction OB025 · one of 8,235 worked contradictions published by CyberTRIZ.AI

Regulations

EU_GDPR NIST_PRIVACY_FRAMEWORK DMBOK DCAM

Business Context

Open Banking enables customers to authorize sharing of financial data with multiple providers, raising questions regarding ownership, responsibility, and lifecycle management.

Banking TRIZ Resolution

Treat customers as the owners of their financial data while banks act as trusted custodians responsible for secure storage, controlled sharing, and transparent consent management.

Recommended Principles

Principle 24 - Intermediary

Principle 25 - Self-Service

Principle 40 - Composite Materials

Expected Outcome

Stronger customer trust

Better data governance

Clear ownership responsibilities

TRIZ principles applied

P24 IntermediaryP25 Self-ServiceP40 Composite Materials

Controls that address this (22)

EU_GDPR-CTRL-001 - Daily safeguarding reconciliationoperational · critical priority · Daily reconciliation between safeguarded customer balances, core ledger balances and safeguarded bank accounts. Variances above EUR 100 must EU_GDPR-CTRL-002 - Critical ICT incident reportingoperational · critical priority · All major ICT incidents impacting payment services, customer data or availability must be classified within 4 hours and reported under DORA EU_GDPR-CTRL-003 - GDPR breach notification workflowoperational · critical priority · Personal data breaches must be assessed within 12 hours and reported to the Belgian DPA within 72 hours where risk to data subjects exists.