An Agile Proposal for a Feasibility Study on a Gifted Account Information Service Provider (AISP) for Research Data

Completed Project Case Study: Unlocking Financial Data for Research

Summary 

Access to real-world financial data has long been one of the most significant barriers for academics researching fintech, consumer protection, and economic policy. Without authentic transaction records, researchers are forced to rely on limited data-sharing agreements or synthetic datasets that fail to capture the full complexity of human financial behaviour. This project set out to explore a bold solution: enabling individuals to “gift” their financial data securely and ethically for research purposes, creating a resource with transformative potential for academia and industry alike. 

The study was led by Professor Daniel Broby, Chair of Financial Technology at Ulster University, and supported by UKFin+ as a feasibility project. Working closely with partners including Fintech NI, Fintech Wales, the Centre for Finance, Innovation and Technology (CFIT), and Smart Data Foundry, the team explored legal, technical, and ethical pathways to building a trusted framework for financial data gifting. 

The Challenge 

While financial data is crucial for tackling questions around inclusion, lending, and consumer wellbeing, strict privacy regulations and commercial sensitivities make it difficult for researchers to access. Agreements that do exist are often opaque and restrictive, while synthetic data lacks the unpredictability of real behaviour. This creates a “data desert” in financial research, limiting evidence-based policy, innovation, and consumer protection initiatives. 

The project asked: How can researchers be given secure and ethical access to authentic banking data, while protecting privacy and maintaining public trust? 

The Research Approach 

The team investigated whether creating a charitable Account Information Service Provider (AISP) specifically designed for academic research would be possible. Using open banking protocols, individuals could choose to donate their financial data, either directly or even posthumously, in the spirit of organ donation or the UK Biobank health model. 

The feasibility study focused on four objectives: securing a legal opinion on financial data gifting, assessing the API development needed to collect and process such data, designing a trust protocol compliant with GDPR, and exploring the potential research applications. 

Agile methods were used, bringing together legal experts, data scientists, regulators, and academics. A one-day focus group with stakeholders across finance and policy helped test the concept, balancing consumer trust with academic needs. 

Key Findings 

The project delivered several important insights: 

  • Legal clarity – A legal opinion confirmed that there is a sound basis for individuals to gift their financial data, providing a foundation for future implementation. 
  • Technical feasibility – Open banking APIs can securely extract financial data, with anonymisation methods have been developed to protect privacy while preserving research value. 
  • Pathway to scale – The study mapped out how a charitable AISP could gather anonymised financial data at scale, opening access to the broader research community. 
  • Research potential – Authentic banking data would enable new research on urgent issues such as payday lending, financial inclusion, and consumer wellbeing, areas where current evidence is sparse. 

The Impact 

The project has already achieved tangible impact. It produced a peer-reviewed paper on the legal basis for financial data gifting and directly informed a larger funding application to UKRI. Industry and policy partners, including Fintech NI, Fintech Wales, CFIT, and Smart Data Foundry, contributed perspectives on compliance, technical delivery, and consumer trust, helping to ensure that the model is rigorous and viable. 

The study also highlighted the potential of building synthetic datasets derived from gifted data, offering another safe pathway for expanding access to financial information while mitigating privacy risks. 

What Happens Next 

The team is now exploring pilot partnerships with charities that support vulnerable groups, such as individuals reliant on payday loans, to demonstrate the social value of financial data gifting. Dissemination efforts continue across academia, industry, and policymaking circles to build momentum toward a UK-wide data gifting infrastructure for finance. 

By unlocking access to authentic banking data, this project has the potential to transform financial research, fuel innovation, and ultimately improve the inclusivity, safety, and fairness of financial services. 

Completed Project Video

Following the completeion of his project Professor Daniel Broby has shared his findings and expereince collaboation with his non – HEI partner.


Original Project Summary

This is a feasibility study for a large-scale financial database and research resource, containing anonymised bank records and financial information gifted by UK individuals. The proposed database will gather this information using an api that makes use of open banking protocols. The study will assess the data privacy, charitable and legal aspects of what would become an important academic resource.

Meet The Team

Professor Daniel Broby

Ulster University

Professor of Financial Technology, Department of Acc, Finance & Economics