Statement of Compliance: Code of Practice for Statistics
Last update: 24/02/2023
The Code of Practice for Statistics is a standard that all providers of official statistics should adhere to. While we do not provide official statistics, at Fable Data we are nonetheless committed to adhering to these practices as a leading provider of alternative data. Here we present our Statement of Compliance for the Code of Practice for Statistics.
Introduction to Fable Data
Fable Data is an award-winning pioneer in the European alternative data market. We own the most comprehensive anonymised dataset of European real time banking and credit card data representing millions of consumers.
As of February 2023, we are solely providers of data, not producers of statistics nor economic indicators. However, we feel that our data has the potential to be incorporated into official statistics or form the basis of a new economic indicator.
Because of this, we aim to voluntarily comply with the Code of Practice for Statistics in a way that is applicable to a commercial entity such as ours, ensuring that we uphold the highest standards in the procurement, governance, and quality of our data.
How the Pillars Guide Fable Data
At Fable, we apply the pillars of the Code of Practice for Statistics (Trustworthiness, Quality and Value) throughout our business model, which can be divided into the three stages:
1. Data Acquisition: before data enters Fable
Key principles :
Data governance
Professional capability
How we comply –
Being a compliance and ethics-driven company, we only ingest data from suppliers whose privacy procedures are up to GDPR standards, and we ensure that the chain of consent is clear and adhered to.
Especially important, we require that the data is anonymised prior to ingestion, thus making it free of personal data and outside the scope of the GDPR. Any demographic data relating to the card user that is ingested is not sufficiently granular to identify that individual, thus complying with the GDPR. For example, our dataset only provides information on age bands rather than the actual age.
Our proprietary compliance technology, which is updated on a regular basis, is available for data suppliers to anonymise their dataset should they need assistance or where masking and redaction has not been carried out to GDPR standard by a data supplier. This privacy technology is applied in the data supplier’s environment to ensure that the data we ingest is GDPR-compliant.
Additionally, our data partners’ identities are protected: only select staff are privy to this knowledge, granted on a need-to-know basis.
Key principles :
Suitable data
Sources: Assured quality
How we comply –
The data we own is anonymised consumer transaction data, sourced directly from the banks and credit card issuers themselves.
Data of this kind has inherent value as transaction data can be delivered close to real-time and is not subject to revisions.
However, we also take certain actions to enhance the quality of the data we receive:
The data is sourced from multiple financial institutions, which can help avoid skew in our dataset
Each prospective supplier is subject to an evaluation to assess data suitability – this includes evaluating the demographic information of dataset to further avoid any excessive skew
Each supplier is on an exclusive contract so that the same data cannot be obtained elsewhere
We are always looking to onboard new suppliers to further improve the quality of our dataset
Key principles –
Efficiency and proportionality
How we comply –
To ensure the sustainability of our data acquisition, all our data suppliers benefit commercially from partnership, and we provide all the necessary compliance and technology support that may be required.
2. Data Enrichment: while data is at Fable
Key principles :
Honesty and integrity
Independent decision making and leadership
Data governance
Professional capability
How we comply –
We have a dedicated Compliance Department with robust internal procedures.
To ensure utmost accountability, the Compliance Department reports to an independent Compliance and Audit Committee, which is formed by Board members and chaired by former government minister David Laws.
Moreover, all staff are required to complete compliance training exercises on range of key topics, such as the GDPR, whistleblowing and conflicts of interest.
Key principles :
Suitable data sources
Sound methods
Assured quality
How we comply –
As the data comes from multiple sources, our expert in-house data and tech team harmonise the data to create a single homogenous and usable dataset.
Our internal data processing ensures that the data is consistently timely – data has always been delivered within our committed time periods.
Our internal benchmarking and economics team inform us of our dataset’s reliability by comparing it to official indicators.
Key principles –
Relevance to users
Clarity and insight
Innovation and improvement
How we comply –
The data is enriched using internal classifications models and external data sources to obtain the raw dataset’s full potential.
For example, transactions are tagged to merchants and stock tickers, and are also combined with socio-demographic information.
To further enhance the usability of the data, we provide a roster of data products with varying levels of granularity depending on client need and capabilities.
3. Data Clients: once data leaves Fable
Key principles :
Data governance
How we comply –
Our clients, who all operate in highly regulated industries, are contractually bound to ensure that the underlying data does not leave their domains/networks.
This contract also specifies that our data cannot be combined with other sources in an attempt to personally identify card users in our dataset.
Key principles :
Suitable data sources
Sound methods
Assured quality
How we comply –
Our engagement with external academic partners helps us to constantly improve internal methodological and benchmarking practices
Key principles –
Relevance to users
Accessibility
Clarity and insight
Innovation and improvement
Efficiency and proportionality
How we comply –
While our data is not freely and equally accessible to all users, we provide our data for free to policymakers and academic researchers in the interest of the public good.
The work produced by our academic partners demonstrates the ability of our data to facilitate innovative research.
The use of our dataset by various government bodies also demonstrates how our data can be key to the policymaking process.
We are also working with national statistical offices in an effort to innovate the compilation of official statistics.
Ensuring the smooth operation of these three key stages cuts across all our teams in the business. Nonetheless, certain teams will have a particular role to play when it comes to upholding each of the Code’s pillars:
Trustworthiness is non-negotiable at Fable Data, and our rigorous Compliance Department is vital to ensuring we are led by data ethics and governance.
Quality is ensured by our Data Partnerships team’s goal to expand our base of suppliers, as well as our Data and Technology team’s expertise in obtaining the full potential of the raw data.
Value for greater society is at the heart of Fable’s Data for Good mission. Our Research Partnerships team supplies our dataset for free to policymakers and academics with the aim of powering innovative research, more informed policymaking, and the next generation of economic statistics.
While we are proud of what the processes we have in place, we are always looking to improve and innovate, and will be guided by the pillars as we do so.
