Segregated Sensitive Data Capture for Compliant Decisioning
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Solution Overview
Problem
Financial institutions face challenges in collecting, storing, and reporting sensitive applicant data while adhering to regulatory standards that require segregation from decision-making processes, such as loan decisioning, to prevent the use of protected demographic data.
Innovation Solution
A system and method for segregated collection and storage of sensitive data using unique identifiers, anonymization, encryption, and homomorphic encryption to separate sensitive data from decisioning data, ensuring compliance with regulatory requirements.
Engineering Contradictions & Design Principles
Engineering Contradiction Analysis
1Reliability
If sensitive data is collected and stored alongside decisioning data, then reporting compliance is simplified, but regulatory compliance is violated due to potential use of protected demographic data in decision-making processes
Solution Approach 1:
The patent divides the data collection and storage system into separate components: one system for collecting decisioning data and another for collecting sensitive demographic data. Each system operates independently with its own database, ensuring that sensitive data cannot be inadvertently used in automated decision-making processes while still allowing for separate reporting compliance.
Solution Approach 2:
The patent introduces a unique identifier as an intermediary element that links decisioning data and sensitive data across separate systems. This identifier enables regulatory reporting by allowing the matching of data from both systems without directly exposing sensitive demographic information to the decisioning process, thus maintaining both compliance and reporting capability.
2Reliability
If sensitive data is segregated from decisioning data, then regulatory compliance is improved, but data matching for reporting becomes more difficult
Solution Approach 1:
The patent extracts the linking function from the sensitive data itself by using a separate unique identifier. This identifier is collected independently and stored separately with the sensitive data, allowing the system to match records for reporting purposes without exposing the actual sensitive demographic information that needs to be protected from decisioning processes.
3Device complexity
If a single system collects both decisioning and sensitive data, then system complexity is reduced, but the risk of compliant use of protected data in decision-making increases
Solution Approach 1:
The patent extracts sensitive demographic data collection into a completely separate system from the decisioning process. This physical and architectural separation ensures that even if the decisioning system has access to all applicant information, it cannot access or use the sensitive demographic data that is stored in an independent, segregated system.
Solution Approach 2:
The unique identifier serves as an intermediary that enables the connection between segregated systems without allowing direct access to sensitive data. The identifier can be used for matching and reporting purposes while the actual sensitive demographic information remains protected in the separate collection system, eliminating the risk of non-compliant use.
Data Source
AI summary
A method may include: an originating system receiving decisioning data from an applicant as part of an application for a product, the originating system redirecting the applicant to a sensitive data capture computer program; the sensitive data capture computer program receiving a unique identifier from the originating system; the sensitive data capture computer program receiving the sensitive data from the applicant, wherein the originating system does not have access to the sensitive data; the sensitive data capture computer program associating the sensitive data with the unique identifier; a matching computer program receiving a decision from the originating system on the application and the unique identifier; the matching computer program receiving the sensitive data and the unique identifier from the sensitive data capture computer program and matching the sensitive data and the decision using the unique identifier; and a compliance reporting program generating a report using the match.