Open Banking Limited (OBL) has employed a number of design and experience principles to create the CEG. This section lays out the principles of informed decision making, providing customers with well-designed experiences (using the principles of control, speed, transparency, security and trust). It also includes information that should be considered in order to support protection of vulnerable customers.
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ASPSPs and TPPs should design customer journeys equivalent to or better than the journeys described in these guidelines in order to deliver the best possible experience and outcomes.
Open Banking products and services must therefore enable:
The Open Banking customer experience must ensure informed decision making while remaining understandable, intuitive and effective. The customer experience must be shaped and positioned into content and functionality that clearly communicates and facilitates purpose, intent and relevance.
This is especially true in a transactional context where customers need to know and understand at all times:
It is essential to move beyond the pure mechanics of the transactional process and into a meaningful, supportive and trusted experience that directly addresses the customer’s needs, goals and concerns. This can be achieved in the way a transaction is structured, but also how it is expressed, designed for and organised around a range of fluctuating human needs.
A series of guiding ‘experience principles’ are outlined here that can be, through careful design, baked into a process or transaction, and dialled up and down where certain interactions become more critical.
These guiding experience principles are deeply customer-centred, shaped by research and insight that reflects and meets specific customer needs. They are used to drive and focus design and User Experience (UX) decisions i.e. what kind of widget, interaction, font, colour, technology, UX and User Interface (UI) best serves the aspirations and requirements of the business but also meets the needs of the customer in simple, effective ways.
Extensive customer research undertaken by Open Banking Ltd (OBL) has demonstrated certain recurring themes that customers deeply care about or are worried by. To promote engagement, understanding and ensure adoption these must be addressed, to varying degrees, within each of the Open Banking customer journeys described in these guidelines.
To support and achieve the goal of creating trust, these themes have been aggregated and synthesised into a number of driving experience principles for Open Banking. These principles underpin the range of core journeys and key customer interactions described throughout these guidelines.
An essential component of trust-building is the provision of a Consent Dashboard by the TPP and an Access Dashboard by the ASPSP. Dashboards encapsulate the Customer Experience principles below and research has consistently shown the fundamental role they play in reassuring customers about the security of open banking-enabled services. In terms of the experience of using a Dashboard, the principles that apply to an authentication journey can be extended to support simple and easy navigation by enabling informed decision making. Please refer to Dashboards to read more.
The introduction of any kind of new transaction, product or service – especially online – can create an opportunity for deeper engagement. However, it can also create barriers through poor implementation. From a consumer perspective, this is often about a perceived sense of control.
If customers feel they understand what is going on in a process, are able to make informed decisions and choices on their own terms – including recourse to change their mind – it provides a sense of ownership and control over what is happening. In a transactional context, where money and data are potentially at stake, getting this right is essential.
For Open Banking, control comes from providing the right tools and clarity of information at the right time (e.g. knowing the exact amount of a transaction at the point of payment, or knowing that they can view and revoke consents given when they feel it is appropriate to do so).
TPPs and ASPSPs need to consider how they provide this sense of ownership and specific optionality throughout – enabling customers to feel this is a process they are both choosing and in charge of.
Speed must be appropriate to the customer and the journey they are undertaking. Convenient, speedy and intuitive design is a question of execution and interaction.
In the transactional context, anything that seems more time consuming or onerous than customers are used to is going to represent a hurdle to adoption. We have to manage and optimise each interaction, as well as hand-off between systems for speed, clarity and efficiency, but without sacrificing the principles of security and control.
In addition, we have to be mindful that the speed of transaction or interaction is not necessarily about the ‘fastest possible’ experience. As we have indicated, we must support informed decision making through comprehension and clarity allowing customers to, above all, move at a pace that suits them.
TPPs and ASPSPs need to ensure that Open Banking customer journeys remain flexible enough to support different customer contexts, expectations and situations and – critically – avoid any unnecessary friction in the completion of any journey.
Transparency of choice, action, and importantly the consequences of actions or sharing of account information is crucial to promoting the benefits of Open Banking, creating engagement and supporting adoption.
In new transactional scenarios where customers are being encouraged to share their financial information this is critical. It is not only about communicating the benefits of a new service, but being explicitly clear on what is required from the customer, why it is required, and for what purposes. Customers need to be able to make an informed decision and, in turn, understand the consequences of that decision.
Sharing information is seen as unavoidable, and a trade-off for convenience and benefits. And while this is a great opportunity for TPPs and ASPSPs, the value exchange for the consumer needs to be explicitly clear.
At the same time, we do not want to overburden the customer or weigh down the business opportunity with excessive explanations. Transparency is about providing progressive levels of information, in plain language, that inform and support customer decisions.
In the context of Security, the key concerns for customers are fraud, which everyone understands, and the use of their account information and how it is protected.
Explicit clarity and reassurance will be required in relation to data definition, usage, security and above all, protection.
As a new service, all security messaging should be clear and reassuring in tone, but not alarmist.
Customers are generally aware of the risks of sharing account information and as expected some types of customer, particularly older demographics, may initially express cautiousness and nervousness.
It is therefore critical to establish and reinforce trustworthiness – trust in the service provider, trust in the transactional process and trust in the role and relationship with their ASPSPs, especially in a payment context where traditional, deeply established alternatives remain available.
The principles of control, speed, transparency and security combine to create a trusted environment for the customer.
TPPs and ASPSPs need to consider, engender and promote values of trust through every part of their Open Banking customer journeys, to foster understanding, acceptance and adoption of new innovative products and services.
Open Banking Limited (OBL), the Implementation Entity described in the CMA Order, undertook considerable customer research over 18 months in order to understand how to enable customers to make informed decisions while enjoying simple and easy navigation and a secure customer journey. A key principle throughout has been to ensure clarity of information, presented and described in a manner that ensures that Open Banking customer journeys are easy to understand, thereby enabling customers to make informed decisions. The results of this research have been shared with stakeholders as the foundations for Open Banking have been established.
OBL recognises that there may be consumers and SMEs who are not yet familiar with Open Banking enabled propositions. They have therefore had to interpret the concepts to be investigated based on their experience and the explanations provided in the research groups or panels. This form of ex-ante research has some limitations as there is often a difference between what customers say they will do and what they then actually do. Observed behaviours and attitudes from respondents have at times been contrary. For example, respondents will express a concern that they want to be secure and protected, but in practice, they value convenience and will react with frustration to complex journeys often skimming the most important information. The consequence of this is that customers may not review the information sufficiently and may make decisions that they might later wish to reconsider. It has become clear that it is extremely important to minimise unnecessary information and process and then to package only the most important information in an easily understandable, intuitive manner so that the customer can actually assimilate the information and therefore make better-informed decisions.
Open Banking Ltd (OBL) research has therefore identified information and steps which assist the customer as well as unnecessary steps, delays, inputs or additional information that may lead to customer frustration and subsequent drop out, or a failure to review the important relevant information. In future research, it is expected that further refinements based on ex-post data will be possible.
We examine the nature of both useful and unhelpful elements of the customer journey below
Customers deemed as vulnerable, or in vulnerable circumstances, may be significantly less able to effectively manage or represent their own interests than the average customer, and more likely to suffer detriment. This may take the form of unusual spending, taking on unnecessary financial commitments or inadvertently triggering an unwanted event. Any customer can become vulnerable at any time in their life, for example through serious illness or personal problems such as divorce, bereavement or loss of income. Work done by the Money and Mental Health Policy Institute in the UK has shown the need to emphasise informed decision-making, with appropriate steps and information in online experiences in order to help those with mental health problems to make informed decisions, understand the potential consequence of their decisions, or even deter a particular course of action.
Entities have a particular responsibility to identify and protect vulnerable customers, needing to pay attention to possible indicators of vulnerability at a holistic level and have policies in place to deal with customers where those indicators suggest they may be at greater risk of harm. For those customers identified as vulnerable, the policies applied should be implemented at a customer level, not at the transaction level or not specifically to Open Banking, just as is the case for vulnerable customers using other products provided by the ASPSP.
ASPSPs should take the following steps for vulnerable customers using products that make use of Open Banking:
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