As a risk, security, fraud, compliance specialist; I should be shouting from the rooftops that this MUST be a great idea to reduce the risks and add a layer of security to the transactions. But in reality, it is not that simple, and veers towards being a big mistake and a legal and operational disaster waiting to happen.
I am also a customer. I am a customer of a bank that issues me with a card and a customer of a retailer where I shop. As a customer of a bank who issues me with a card, I might be happy to let them have a picture of me to put on my card or to make sure that it is me that visits their ATM. But when I signed up for a trial 20 years ago for this, I had to give explicit consent for my issuer to store and use these details on the card and on their systems.
In this case, it is not my issuer that is collecting my photograph or checking it. It is not even the retailer that I am transacting with who is collecting it; it is the bank who is processing the card for the merchant; and as a customer, I DO NOT WANT MY PHOTO taken, kept or processed by the retailer, nor do I want the merchant’s acquirer to keep or store it without my consent.
This is an invasion of my privacy. Do not do it. You have no consent from me to take, keep, store or use my personal details (my photo and card details) for any other purpose than is necessary to undertake the transaction. Indeed, you should be encrypting and anonymising my personal details as is required by many anti-fraud measures, and mandates in-play at the moment. Just how legal this is we will no doubt learn from the Information Commissioner in days, weeks to come. The fraud issue is one for my card issuer, and is of no interest to the acquirer (or merchant) so long as I use a card with a CHIP and a PIN and an EMV protocol.
OK – so in the customer journey, there is no justification, but what about the security. We have already established that this is not the acquirer’s problem. The acquirers need to focus their attentions upon making their part of the process secure, with encryption, stronger depersonalisation (tokenisation) of the transaction, storing less data, and not losing data. They should also focus upon looking for unusual transactions that are likely to cause future difficulties and improving security at the till, staff training, improving merchant awareness, ensuring PCI DSS conformity and clarity and better terminal and tampering awareness and notifications; all of which could help stop compromises, data theft and attacks that cause £€$millions in losses and crime at the point of sale.
It is a pure folly to introduce a ‘photo at the point of sale’ (as well as a customer invasion of privacy), and certainly NOTHING to do with improved security or reduced fraud: and a big diversion from more important things that MUST be done at the point-of-sale to help security, and help the merchants.
Equally, it is not too great a security foundation to start letting ALL acquirers (WorldPay is one of many 100s globally) store data somewhere without controls. And how legal is it for them to store pictures for those from other countries, or of a picture of my child hanging on to me.
I would suspect that the eye catching ‘biometric trials’ headlines will make it all sound like a good idea, and let’s all applaud Worldpay for ‘doing something’ – even if it has not been fully thought out yet. But I would suspect that these trials are not very big at all yet – maybe just a staff canteen? – as the legal issues may not yet have been addressed or looked at properly yet. I am also certain that the Information Commissioner will not have been involved either – but I’d hope it will be on the agenda with Christopher Graham’s when I see him tomorrow morning!
The whole industry though is also racing faster into biometrics with fingerprints via Applepay and Androidpay / Googlepay etc. with the added security of tokenisation, secure element, customer control of the biometric (i.e. it is stored nowhere other than on the phone by the customer), etc. So, what happened to the transaction if there is no PIN, or if it is an NFC payment. Mmmmmm – more thinking to be done somewhere about where all this is going.
And let’s not ignore the issues around whether I change my hairstyle, make-up, or remove my beard this week, wrap-up warmer with a hat as we will do next month etc.
Is this allowed by the schemes? Is there a compliance issue here? Yes – dammed right there is; The message collected with the card must comply to a format, the full messaging must be sent to the issuer, and it is the issuer that must make the authorisation decision about the customer – NOT THE ACQUIRER. If the card schemes have been involved and/or permitted this – which I doubt – then the normal route that is taken with these things is for the scheme to join in with the publicity and announcements – which I have not yet seen.
Great idea Worldpay, great initiative, but it is not for me as a customer, as a merchant, nor as an issuer or as a card scheme.