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having access to it. While this may be a limitation for Standards also might identify certain data that are
telecommunications operators use of data they hold, potentially very sensitive, such as location data, and
it will be an opportunity for others. build in measures to protect such data such as cri-
teria for access to them, controls on the purposes
6.1.4 Competitive strategy for which they may be used, and how such data
Where operators have recognised the value of the should be deleted. Anonymisation and other privacy
data, they may be competing with others in the enhancing technologies might also be agreed upon
services they seek to use it for, such as banks and for standard use.
fintech companies. Telecommunications operators Standards could also provide for the use of unique
may seek to exploit the specific advantages they identifiers (e.g., national ID numbers) across data
enjoy from their privileged control over telecommu- sets to allow for richer layers of data to be used, but
nications data. Even if they do not do so immediately, coupled with careful measures to mitigate risks to
they may prefer not to provide access to the data privacy from combining personally identifiable infor-
but preserve later opportunities. Mobile operators mation.
are not necessarily easy partners, preferring to retain Some basic parameters for explaining to consum-
tight control over the customer relationship. ers how data has been used could be included in
standards. Standards could also set out principles
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6.1.5 Organisation of data or mechanisms enabling customers to have recourse
Even where telecommunications operators do if data about them is used without a proper legal
wish to make full use of data they hold, they may basis, or is misused, or is incorrect (e.g., due to being
not have organised the data in a manner to make it out of date or erroneous).
readily usable for profitable purposes, whether by Such standards could also set out the types of
themselves or third parties. It may be held in differ- organisations that could access such data, and the
ent forms, some structured and some unstructured, purposes for which they might legitimately do so. This
neither combined nor cross-referenced. In particular, could include standards for verifying such organisa-
various different data sets about the same customers tions and their claimed purposes, for authenticating
may not have a common unique identifier (such as a their identities, for controlling which data they may
national ID number) enabling insights to be drawn have access to, and measures for limiting their use
from combining such data. and access to the purpose for which it is permitted.
For all of these reasons, telecommunications data Such common standards would serve several
remains under-utilised, and it often takes third par- purposes of improving the usefulness of data when
ty expertise and a partner to prompt the operator made available. If implemented widely, this would
to take steps to use the data or make it available to create an externality of increasing the overall val-
others. ue of all data for social benefit because data are so
much more useful when aggregated at large scale.
6�2 The potential of standards Common standards would also support the legitima-
Useful work has been carried out to develop stan- cy of using such data. Regulatory authorities could
dards and ethical guidelines for use of AI in digital endorse the international standards, or even adopt
financial services. Despite extensive excitement them into their domestic regulations.
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about the potential of data, however, a gap remains These measures should significantly reduce the
with respect to access to data in the manner and regulatory risk that telecommunications operators
scale that uses it to its potential value. face. The creation of value and reduction of risk
There are various reasons to think that the devel- would significantly increase the incentives for tele-
opment of internationally recognised standards communications operators to use and allow third
could help. Standards could be prepared identify- parties to use data they hold.
ing what telecommunications data should be made
available, and setting out how it should be collected 6�3 A wider vision for use of telecommunications
and organised by telecommunications companies. data
To begin with, not all data are as useful as oth- The development of standards would also encourage
ers. Standards might help form a consensus focused telecommunications operators to see the opportuni-
on data that really have value, such as certain call ty of the data they hold at many levels, beginning
patterns or billing data, and to prioritise organising (where they do not already) to improve profitability
these so they can be available in a common format. of their core telecommunications business. They may

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