Question

Topic: Research/Metrics

Benchmarking - Anonymous Information Sharing

Posted by Anonymous on 125 Points
To what extent can you share specific data about customers if it is aggregated and anonymous?

Background:
I work in insurance serving a very specific industry. I collect alot of data. I have non-competitive colleagues around the country also focused on this same niche. I would like to create a benchmark report that details important trends in our clients' industry. I want to provide trending data for premiums and claims, so I can tell my clients what other folks like them are paying, and what kind of claims their peers are having.

The concern is privacy. Is it legal to do this just using my own client information? What if I want to aggregate data from around the country? What if I stripped the identify information (company name, etc.) but just reported information about the type of company and their premium and claims info- would that be legal? Would I need to get written permission from each client to do so? Could I put an opt-out disclaimer in our client agreements regarding this particular use of their information?
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RESPONSES

  • Posted by Chris Blackman on Accepted
    The question seems ambiguous: If the data is really anonymous and aggregated, how can it be specific about any particular customer?

    By the way, there is really no such thing as "my own client information". Under any privacy legislation I know, client information belongs to the client, you are merely the guardian or custodian of it.

    If you aggregate by segment types and/or geographic characteristics, e.g. postal or zip code, then there should be no problem publishing information at that level.

    As soon as you publish information that is recognisable or traceable back to a company or individual, then you have failed to maintain the privacy you may have contracted to provide. So you might remove the name of the client, but still leave them clearly identifiable, to someone with internet access and deductive powers, if you describe them, say as a xyz type business with 100-150 employees in Raleigh, NC.

    If in any doubt, I would seek an opinion about what you plan to do from a suitably qualified legal practitioner in your jurisdiction and/or the jurisdictions in which your customers are based, and where you intend to publish the information, if different from your domiciled jurisdiction.

    I think you can achieve what you want to achieve by aggregating up into chunks of no smaller than (say) 50 clients in a group, perhaps by postal (zip) code, business size, business type, but not providing cross-tabbed information that would allow drill-down to identify any particular business or group of businesses.

    And I would not take the path of "opt-out" disclaimers. Your clients deserve privacy, and the trend-type data you are trying to provide does not require individual clients to be identified. Trends are higher level than that. If it doesn't apply to a segment or over a period of time, how can it be a trend?

    Hope this helps.
  • Posted by Chris Blackman on Member
    Philip

    I think I probably also speak for other KHE members when I say how much I appreciate your professional feedback and timely participation in this forum.

    It's a pleasure to help someone who acknowledges the input they receive, and which parts were of most value. I shall look forward to your further participation in the future!

    ChrisB

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