Why research is critical for developing digital identity technology
Onfido is a global identity verification provider, headquartered in the UK that uses AI and biometric technology to confirm real identities online. This allows its customers to remotely verify and authenticate their users in a safe, secure way that fully respects their privacy.
Our research activity
Research is a critical element of Onfido’s success, and it takes various forms. First and foremost our Center of Applied AI conducts a rolling programme of research into AI bias mitigation and optimising algorithmic performance in order to continually improve our product. This ultimately enhances outcomes for both our customers and their end users.
We also conduct collaborative research. One recent example is the pioneering research Onfido conducted in partnership with the ICO, where we investigated the data protection and privacy issues associated with training algorithms. This culminated in a report issued by the ICO that can be found here, in which it stated how “immensely grateful” it was for the research Onfido carried out and the resulting findings. This enabled the ICO to better understand the way in which AI works and informed its subsequent guidance for industry.
Onfido also conducts academic research to contribute to the wider body of literature on AI. It publishes some of the work carried out by its data scientists to help educate and inform the wider industry about vital issues of bias and how to mitigate its effects.
There is a very clear public interest associated with the research that Onfido fulfills. This is because our product is a vital tool in the fight against fraud. It is used widely by financial services customers to comply with their regulatory obligations associated with fraud prevention, in particular anti-money laundering and know-your-customer rules.
The research we conduct is essential to driving innovation, and in turn improving the quality of the deterrent against fraud. This drives huge societal benefits and a better level of consumer protection for customers using our product. A research-friendly regime needs to be supported and reinforced through relevant legislative provisions in order that we can point to a clear mandate to carry out this work.
Current barriers to research
There is much confusion as to the scope of and application of the current research-specific provisions. Identifying a lawful basis for research purposes can create a particular challenge for companies that are (i) dependent on another controller to collect and provide personal data; and/or (ii) reusing personal data collected for one purpose for research. For example the controller who collected the data may have relied on explicit consent for the original processing. This can limit the data available for research where the consent was too narrow and/or the transparency obligations not sufficient to enable the reuse of data.
For innovative companies such as Onfido, who provide AI driven services to corporate clients, these challenges present barriers that do not exist for bigger technology companies that can afford and have the data to build AI services in house. Such companies often have direct relationships with end users and/or control more of the user journey/technology ecosystem and therefore can avoid some of these difficulties.
The lack of appropriate provisions for research can create unease for customers and can add friction and delays to the sales process as they seek to get comfortable with the use of data for research purposes. A clear statutory definition of research, which includes research undertaken by a commercial organisation, would help increase certainty, and we would strongly encourage this to include a specific reference to commercial research including for the purpose of identifying and/or developing new technologies, or new uses of existing technologies.
Simplifying and consolidating the research-specific provisions will remove barriers to growth and innovation in the UK, and help incentivise companies like Onfido to drive product improvements that contribute to better outcomes for society.
This blog is part of a series exploring the UK's upcoming reform to its data protection regime. Learn more here.
Matt is Onfido's Global Director of Public Policy. He has nearly 20 years experience in public policy roles in telecoms and technology. Prior to Onfido, he spent over 10 years as Head of Policy for UK and Ireland at Verizon, the US tech giant, overseeing policy across a range of areas including digital competition, cyber security and privacy. Matt holds a law degree (UEA), MBA (Henley Business School), post-graduate diploma in Competition Law (Kings College) and diploma in business international relations and the political economy (London School of Economics).