Enact legislation to establish a national financial and personal data retention policy (max 18 months for unproven/low-severity fraud markers); prohibit use of financial fraud data for non-core sectors insurance, job screening etc; create a tribunal to challenge POCA-constrained de-banking evidence.
Introduce laws for Mandatory Tiered Data Retention (1) and Statutory Purpose Restriction on data sharing (2) to prevent 'purpose creep' into employment/insurance. Establish a tribunal with Judicial Review type powers with statutory privilege to scrutinise POCA-constrained evidence for de-banking filings, to ensure due process without tipping off (3). We ask the Government to amend legislation to expand the FCA's powers to enforce Consumer Duty on data.