The Role of Identity Management in the GDPR

Unless you have been living in a darkened room for a long time, you will know the countdown for the EU's General Data Protection Regulation is dramatically coming to a head.  May 2018 is when the regulation really takes hold, and organisations are fast in the act on putting plans, processes and personnel in place, in order to comply.

Whilst many organisations are looking at employing a Data Privacy Officer (DPO), reading through all the legalese and developing data analytics and tagging processes, many need to embrace and understand the requirements with how their consumer identity and access management platform can and should be used in this new regulatory setting.

My intention in this blog, isn't to list every single article and what they mean - there are plenty of other sites that can help with that.  I want to really highlight, some of the more identity related components of the GDPR and what needs to be done.

Personal Data

On the the personal data front, more and more organisations are collecting more data, more frequently than ever before.  Some data is explicit, like when you enter your first name, last name and date of birth when you register for a service for example, through to the more subtle - location, history and preference details amongst others. The GDPR focuses on making sure personal data is processed legally and data is only kept for as long as necessary - with a full end user interface that has the ability to make sure their data is up to date and accurate.

It goes with out saying, that this personal data needs to have the necessary security, confidentiality, integrity and availability constraints applied to it.  This will require the necessary least privileged administrative controls and data persistence security, such as the necessary hashing or encryption.

Lawful Processing

Ah the word law! That must be the legal team. Or the newly appointed DPO. That can't be a security, identity or technology issue.  Partially correct. But the lawful processing, also has a significant requirement surrounding the capture and management of consent.  So what is this explicit consent? The data owner - that's Joe Blogs whose data has been snaffled - needs to be fully aware of the data that has been captured, why it is captured and who has access.

The service provider, also needs to explicitly capture consent - not an implicit "the end user needs to opt out", but more the end user needs to "opt-in" for their data to be used and processed.  This will require a transparent user driven consent system, with sharing and more importantly, timely revocation of access.  Protocols such as User Managed Access may come in useful here.

Individuals Right to be Informed

The lawful processing aspect, flows neatly into the entire area of the end user being informed.  The end user needs to be in a position to make informed decisions, around data sharing, service registration, data revocation and more.  The use of 10 page terms and conditions thrust down the end user's screen at service startup, are over.

Non-tech language is now a must, with clear explanations of why data has been captured and which 3rd parties - if any - have access to the data.  This again flows into the consent model - with the data owner being able to make consent decisions, they need simple to understand information.  So registration flows will now need to be much more progressive - only collecting data when it is needed, with a clear explanation of why the data is needed and what processing will be done with it.  20 attribute registration forms are dead.

Individuals Right to Rectification, Export and Erasure

Certainly some new requirements here - if you are a service provider, can you allow your end users to clearly see what data you have captured about them, and also provide that data in a simple to use end user dashboard where they can make changes and keep it up to date?  What about the ability for the data owner to export that data in a machine readable and standard format such as CSV or JSON?

Right to erasure is also interesting - do you know where your end user data resides?  Which systems, what attributes, what correlations or translations have taken place?  Could you issue a de-provisioning request to either delete, clean or anonymize that data? If not you may need to investigate why and what can be done to remediate that.


Conclusion

The GDPR is big.  It contains over 90 articles, containing lots of legalese and fine grained print.  Don't just assume the legal team or the newly appointed DPO will cover your company's ass.  Full platform data analytics tagging will be needed, along with a modern consumer identity and access management design pattern.  End user dashboards, registration journeys and consent frameworks will need updating.

The interesting aspect, is that privacy is now becoming a competitive differentiator.  The GDPR should not just be seen as an internal compliance exercise.  It could actually be a launch pad for building closer more trusted relationships with your end user community.

The Role of Identity Management in the GDPR

Unless you have been living in a darkened room for a long time, you will know the countdown for the EU's General Data Protection Regulation is dramatically coming to a head.  May 2018 is when the regulation really takes hold, and organisations are fast in the act on putting plans, processes and personnel in place, in order to comply.

Whilst many organisations are looking at employing a Data Privacy Officer (DPO), reading through all the legalese and developing data analytics and tagging processes, many need to embrace and understand the requirements with how their consumer identity and access management platform can and should be used in this new regulatory setting.

My intention in this blog, isn't to list every single article and what they mean - there are plenty of other sites that can help with that.  I want to really highlight, some of the more identity related components of the GDPR and what needs to be done.

Personal Data

On the the personal data front, more and more organisations are collecting more data, more frequently than ever before.  Some data is explicit, like when you enter your first name, last name and date of birth when you register for a service for example, through to the more subtle - location, history and preference details amongst others. The GDPR focuses on making sure personal data is processed legally and data is only kept for as long as necessary - with a full end user interface that has the ability to make sure their data is up to date and accurate.

It goes with out saying, that this personal data needs to have the necessary security, confidentiality, integrity and availability constraints applied to it.  This will require the necessary least privileged administrative controls and data persistence security, such as the necessary hashing or encryption.

Lawful Processing

Ah the word law! That must be the legal team. Or the newly appointed DPO. That can't be a security, identity or technology issue.  Partially correct. But the lawful processing, also has a significant requirement surrounding the capture and management of consent.  So what is this explicit consent? The data owner - that's Joe Blogs whose data has been snaffled - needs to be fully aware of the data that has been captured, why it is captured and who has access.

The service provider, also needs to explicitly capture consent - not an implicit "the end user needs to opt out", but more the end user needs to "opt-in" for their data to be used and processed.  This will require a transparent user driven consent system, with sharing and more importantly, timely revocation of access.  Protocols such as User Managed Access may come in useful here.

Individuals Right to be Informed

The lawful processing aspect, flows neatly into the entire area of the end user being informed.  The end user needs to be in a position to make informed decisions, around data sharing, service registration, data revocation and more.  The use of 10 page terms and conditions thrust down the end user's screen at service startup, are over.

Non-tech language is now a must, with clear explanations of why data has been captured and which 3rd parties - if any - have access to the data.  This again flows into the consent model - with the data owner being able to make consent decisions, they need simple to understand information.  So registration flows will now need to be much more progressive - only collecting data when it is needed, with a clear explanation of why the data is needed and what processing will be done with it.  20 attribute registration forms are dead.

Individuals Right to Rectification, Export and Erasure

Certainly some new requirements here - if you are a service provider, can you allow your end users to clearly see what data you have captured about them, and also provide that data in a simple to use end user dashboard where they can make changes and keep it up to date?  What about the ability for the data owner to export that data in a machine readable and standard format such as CSV or JSON?

Right to erasure is also interesting - do you know where your end user data resides?  Which systems, what attributes, what correlations or translations have taken place?  Could you issue a de-provisioning request to either delete, clean or anonymize that data? If not you may need to investigate why and what can be done to remediate that.


Conclusion

The GDPR is big.  It contains over 90 articles, containing lots of legalese and fine grained print.  Don't just assume the legal team or the newly appointed DPO will cover your company's ass.  Full platform data analytics tagging will be needed, along with a modern consumer identity and access management design pattern.  End user dashboards, registration journeys and consent frameworks will need updating.

The interesting aspect, is that privacy is now becoming a competitive differentiator.  The GDPR should not just be seen as an internal compliance exercise.  It could actually be a launch pad for building closer more trusted relationships with your end user community.

Gartner Identity Summit London 2015 – Review

This week saw the Gartner Identity and Access Management Summit come to London town.  The event brings together the great and good from the identity community, with a range of vendors, consultancies and identity customers all looking to analyse the current market place and understand the current challenges as well as hot topics that can be applied in 2015 and beyond.

Hitting the Right Notes

The main keynote from the external speaker, was from the highly talented classical musician Miha Pogacnik.  Miha delivered an inspirational 60 minute talk, translating the components of classical music into the realm of business transformation.  He focused on organisational change and all the various different angles of repetition, aggression, questioning and responding that occur and the new challenges it places on organisations, whilst playing a piece of Bach on his violin!  Fantastic.



Consumers Have Identities Too

From a strategic identity perspective, there were several presentations on the developing need for consumer identity management. Many organisations are embracing digital transformation in both the private and public sector, defining use cases and requirements for things like consumer registration, authentication and multi-factor authentication, all done within a highly scalable yet simple identity management framework.

Traditional identity management platforms, products and delivery approaches, are often focused on small scale, repeatable use cases that focus on employees and workflow and don't require the scale or rapid time to delivery that consumer facing projects need.

Gartner's Lori Robinson went through the journey of differences between customer and employee identity management and how features such as consumer registration, map neatly to core provisioning and synchronization use cases, whilst features such as authentication are being extended to include things like adaptive risk, device finger printing and the use of one time passwords to help improve security when high value consumer transactions take place, such as address changes.

The Identity of Things Headache

Another emerging area that not only Gartner, but many consultants and customers were talking about, was that of applying identity patterns to devices and things.  Whilst there has been the initial hype of consumer focused things - such as fitness trackers, fridge monitors and so on - there is a great and developing need for identity and access patterns to the manufacturing space, utilities, SCADA and energy sectors.  Many devices are low powered and have limited cryptographic processing capabilities, but still require registration and linking use cases to be fulfilled as well as having the data their generate to be protected.

The linking, relationship building and data privacy concerns of the newly emerging internet of things landscape, requires heavy doses of identity and access management medicine to make them sustainable.

Newer emerging standards such as OpenID Connect and User Managed Access were the main focus of the coffee chatter and how they can provide federated authorization capabilities to both people and things based infrastructures.


Overall it was a well attended and thought provoking summit, with both traditional and emerging vendors sponsoring and some great event party antics.  It seems the identity management space is going from strength to strength, even after being around for over 15 years.  The new challenges of devices, consumers, cloud and mobile are helping to drive innovation in both the vendor and delivery space.

By Simon Moffatt



Gartner Identity Summit London 2015 – Review

This week saw the Gartner Identity and Access Management Summit come to London town.  The event brings together the great and good from the identity community, with a range of vendors, consultancies and identity customers all looking to analyse the current market place and understand the current challenges as well as hot topics that can be applied in 2015 and beyond.

Hitting the Right Notes

The main keynote from the external speaker, was from the highly talented classical musician Miha Pogacnik.  Miha delivered an inspirational 60 minute talk, translating the components of classical music into the realm of business transformation.  He focused on organisational change and all the various different angles of repetition, aggression, questioning and responding that occur and the new challenges it places on organisations, whilst playing a piece of Bach on his violin!  Fantastic.



Consumers Have Identities Too

From a strategic identity perspective, there were several presentations on the developing need for consumer identity management. Many organisations are embracing digital transformation in both the private and public sector, defining use cases and requirements for things like consumer registration, authentication and multi-factor authentication, all done within a highly scalable yet simple identity management framework.

Traditional identity management platforms, products and delivery approaches, are often focused on small scale, repeatable use cases that focus on employees and workflow and don't require the scale or rapid time to delivery that consumer facing projects need.

Gartner's Lori Robinson went through the journey of differences between customer and employee identity management and how features such as consumer registration, map neatly to core provisioning and synchronization use cases, whilst features such as authentication are being extended to include things like adaptive risk, device finger printing and the use of one time passwords to help improve security when high value consumer transactions take place, such as address changes.

The Identity of Things Headache

Another emerging area that not only Gartner, but many consultants and customers were talking about, was that of applying identity patterns to devices and things.  Whilst there has been the initial hype of consumer focused things - such as fitness trackers, fridge monitors and so on - there is a great and developing need for identity and access patterns to the manufacturing space, utilities, SCADA and energy sectors.  Many devices are low powered and have limited cryptographic processing capabilities, but still require registration and linking use cases to be fulfilled as well as having the data their generate to be protected.

The linking, relationship building and data privacy concerns of the newly emerging internet of things landscape, requires heavy doses of identity and access management medicine to make them sustainable.

Newer emerging standards such as OpenID Connect and User Managed Access were the main focus of the coffee chatter and how they can provide federated authorization capabilities to both people and things based infrastructures.


Overall it was a well attended and thought provoking summit, with both traditional and emerging vendors sponsoring and some great event party antics.  It seems the identity management space is going from strength to strength, even after being around for over 15 years.  The new challenges of devices, consumers, cloud and mobile are helping to drive innovation in both the vendor and delivery space.

By Simon Moffatt



Online-ification: The Role of Identity

The Wikipedia entry for Digital Transformation, "refers to the changes associated with the application of digital technology in all aspects of human society".  That is a pretty broad statement.

An increased digital presence however, is being felt across all lines of both public and private sector initiatives, reaching everything from being able to pay your car tax on line, through to being able to order a taxi based on your current location.  This increased focus on the 'online-ification' of services and content, drives a need for a loosely coupled and strong view of an individual or thing based digital identity.

Digital Theme I - Physical to Digital

The classic digital transformation approach that many organisations are going through, generally focusses on the structural change of delivering an on line service that was previously sold in a more face to face manner.  Insurance is a simple example.  20 years ago (or even less..) brokers were common place - high street independents that provided advice and guidance on purchasing insurance for a range of common scenarios, from cars and homes, to health.  Roll forward to 2014, and you can get aggregated quotes in minutes, simply by going through an exchange of personal information with a website.

Whilst this requires greater decision making on consumer side - being able analyse and consume complex information - the ability to reach more customers in a quicker manner, is now a standard mantra for many CEO's.

The main driver of course, is competitive advantage.  If you are not providing your service on line, somebody else will.  This results in rapidly evolving web sites, delivery platforms and profile management solutions, that take only months if not weeks to implement.  Speed and agility are key here.

Digital Theme II - Increasing Self Service

From a cost perspective, getting existing customers into the mindset of self-service is a game changer.  Less reliance on call centre staff, branches and again narrowing the field of vision when it comes to face to face communication.  The interaction with a physical person brings not only cost, but friction, when it comes to executing simple information exchange transactions.  If the service or piece of information being exchanged can be commoditized, or at least treated in a repeatable manner, self-service is a no-brainer.  The most simple example, is password reset or being able to update a users own profile or details.  But this again requires strong identity verification and authorization processes to be successful.

Digital Theme III - Introducing New Services

Whilst themes I and II are more focused on existing customers - and ultimately keeping them happy and being "sticky" towards your organisation, service or good, the introduction of new services is often about expanding and looking for entirely new users and customers. Of course, cross selling and up selling something new into your existing customer base is key, but attracting new users is the "rain making" mantra of sales VP's up and down the land - Net New Business.  Attracting new customers is one thing, getting to sign up to a new service is something entirely different.  There needs to simple and transparent registration processes - perhaps reusing identity attributes from social media providers for example - but providing enough of a carrot, so that the user is happy to exchange their contact and user details in order to either buy or consume a service from you.

Identity at the Core

Throughout the above themes, identity is front and central.  Existing customers need to be set up, transferred or reconciled, in order to have a digital presence.  They require notifications, training, and login credentials, so they can access goods and services to at least the same level as they did when a face to face or physical transaction took place.  Just think of that for a second - 'to at least the same level as they did when a face to face or physical transaction took place'.  That is a big statement.  An on line service that is replacing something physical, cannot be any worse!  It will certainly be different, but it must be at least on parity and hopefully an improvement on the previous ways of working.

There also needs to be effective methods of not only registering a user, but allowing a relatively seamless and transparent method of logging in - single sign on, contextual based login, perhaps taking a device finger print - as well as the reuse of existing identity attributes and passwords through the "bring your own identity" concept.

Identity is core, but it is also often taken for granted.  Security aspects need to be simple and robust - the use of things like one time passwords, not only increase the secure theatre, but should also help reduce risk.

So whilst digital is everywhere, having a strong focus on identity management will help not only fulfil the promise of delivering existing content in a new medium, but help to attract new users and consumers to your organisation.

By Simon Moffatt

Online-ification: The Role of Identity

The Wikipedia entry for Digital Transformation, "refers to the changes associated with the application of digital technology in all aspects of human society".  That is a pretty broad statement.

An increased digital presence however, is being felt across all lines of both public and private sector initiatives, reaching everything from being able to pay your car tax on line, through to being able to order a taxi based on your current location.  This increased focus on the 'online-ification' of services and content, drives a need for a loosely coupled and strong view of an individual or thing based digital identity.

Digital Theme I - Physical to Digital

The classic digital transformation approach that many organisations are going through, generally focusses on the structural change of delivering an on line service that was previously sold in a more face to face manner.  Insurance is a simple example.  20 years ago (or even less..) brokers were common place - high street independents that provided advice and guidance on purchasing insurance for a range of common scenarios, from cars and homes, to health.  Roll forward to 2014, and you can get aggregated quotes in minutes, simply by going through an exchange of personal information with a website.

Whilst this requires greater decision making on consumer side - being able analyse and consume complex information - the ability to reach more customers in a quicker manner, is now a standard mantra for many CEO's.

The main driver of course, is competitive advantage.  If you are not providing your service on line, somebody else will.  This results in rapidly evolving web sites, delivery platforms and profile management solutions, that take only months if not weeks to implement.  Speed and agility are key here.

Digital Theme II - Increasing Self Service

From a cost perspective, getting existing customers into the mindset of self-service is a game changer.  Less reliance on call centre staff, branches and again narrowing the field of vision when it comes to face to face communication.  The interaction with a physical person brings not only cost, but friction, when it comes to executing simple information exchange transactions.  If the service or piece of information being exchanged can be commoditized, or at least treated in a repeatable manner, self-service is a no-brainer.  The most simple example, is password reset or being able to update a users own profile or details.  But this again requires strong identity verification and authorization processes to be successful.

Digital Theme III - Introducing New Services

Whilst themes I and II are more focused on existing customers - and ultimately keeping them happy and being "sticky" towards your organisation, service or good, the introduction of new services is often about expanding and looking for entirely new users and customers. Of course, cross selling and up selling something new into your existing customer base is key, but attracting new users is the "rain making" mantra of sales VP's up and down the land - Net New Business.  Attracting new customers is one thing, getting to sign up to a new service is something entirely different.  There needs to simple and transparent registration processes - perhaps reusing identity attributes from social media providers for example - but providing enough of a carrot, so that the user is happy to exchange their contact and user details in order to either buy or consume a service from you.

Identity at the Core

Throughout the above themes, identity is front and central.  Existing customers need to be set up, transferred or reconciled, in order to have a digital presence.  They require notifications, training, and login credentials, so they can access goods and services to at least the same level as they did when a face to face or physical transaction took place.  Just think of that for a second - 'to at least the same level as they did when a face to face or physical transaction took place'.  That is a big statement.  An on line service that is replacing something physical, cannot be any worse!  It will certainly be different, but it must be at least on parity and hopefully an improvement on the previous ways of working.

There also needs to be effective methods of not only registering a user, but allowing a relatively seamless and transparent method of logging in - single sign on, contextual based login, perhaps taking a device finger print - as well as the reuse of existing identity attributes and passwords through the "bring your own identity" concept.

Identity is core, but it is also often taken for granted.  Security aspects need to be simple and robust - the use of things like one time passwords, not only increase the secure theatre, but should also help reduce risk.

So whilst digital is everywhere, having a strong focus on identity management will help not only fulfil the promise of delivering existing content in a new medium, but help to attract new users and consumers to your organisation.

By Simon Moffatt

Would You Sell Your Privacy for Service Improvement?

When you put the question so bluntly, most people would probably say no.  But in reality this is the common situation many users face when signing up to cloud services, applications and retail sites.

Think of the following common scenario:  you want to get a quote for car insurance / car valuation / current house price or similar.  You will probably be faced with several click through forms where you fill in the necessary product information.  But, and there's always a but, you then need to fill in some personal contact information as a minimum before you are provided with the information you're looking for.  A sort of exchange of data for data.  Just so happens yours is personal.  In addition, you may also need to sign away how that personal data is going to be used.  Perhaps marketing emails or letters via the service provider themselves, or perhaps by a 'trusted' third party.  A final, more subtle exchange of data, is that the service provider now clearly knows you are looking for new insurance / moving house / selling your car.  That is quite a powerful personal context to each of those scenarios.

Is The Exchange of Information Worth It?

This is obviously a subjective question as the information you exchange will have a different value to each data owner.  You could argue that personal contact information is pretty much public domain anyway.  They have been Yellow Page equivalents and directory enquiries facilities for decades.

Finding someones personal or work email address is also pretty trivial these days, simply as they are so commonly used to sign up to so many services.  Many also will take the view, that if someone does send you a marketing or spam email, your ISP filters will simply place it into a junk folder and no harm is done.

If in return, you receive a free white paper, document, quote, temporary access to a new service, or signup to a freemium product perhaps giving away some personal contact information is a good deal?

However, what happens to the data that is harvested?  Where does it end up?  Contact information is one thing, but adding in additional details such as your personal circumstances, how many people live in your property if it's for an insurance quote for example, or perhaps releasing your mobile number, could result in future impacts on your privacy.

Is There An Impact On Privacy?

Again this could be a subjective answer.  There have been many discussions in the past 36 months regarding government surveillance of both individuals and government officials.  I am not an advocate for or against surveillance, but was there a physical impact on the individual during the snooping?  Note the word during.  Many people talked about the invasion of privacy and human rights, but that was only after they knew they had been observed.  The reaction was generally a retrospective one, not an active one.  That is not to say it's less valid, but the context needs to be applied.  The same could be said regarding commercial use of personal data. It's all good, until it isn't.  Whilst no one uses your personal data maliciously, is there a problem to address?  This can probably be classified in the same file as the infamous 'unknown unknowns' approach to threat intelligence by the US government.

eCommerce, Digitization and 'Sticky' Customers

Many organizations have no interest in using personal data maliciously.  The increased digitization of previously physical services and the increased use of online retail, has lead many organizations trying to get a better picture of their consumers, customers and potential customers.  Note the subtle difference between a consumer (who is actively using a service perhaps without registration eg Google), a customer (paying for a service or good) and potential customer.  All have different characteristics from a marketing and customer servicing perspective.  A organisation wants to get the individual perhaps down a consumer --> customer --> repeat/upselling customer route as quickly as possibly, but with a stickiness towards the latter part of the journey - ie when they're a customer keep hold of them.

The information exchange at the beginning of that cycle is key to helping organisations follow that flow.  From a individuals perspective, there needs to be a strong service improvement or cost saving aspect in order to sacrifice some of the data that is being asked for.

By Simon Moffatt



Would You Sell Your Privacy for Service Improvement?

When you put the question so bluntly, most people would probably say no.  But in reality this is the common situation many users face when signing up to cloud services, applications and retail sites.

Think of the following common scenario:  you want to get a quote for car insurance / car valuation / current house price or similar.  You will probably be faced with several click through forms where you fill in the necessary product information.  But, and there's always a but, you then need to fill in some personal contact information as a minimum before you are provided with the information you're looking for.  A sort of exchange of data for data.  Just so happens yours is personal.  In addition, you may also need to sign away how that personal data is going to be used.  Perhaps marketing emails or letters via the service provider themselves, or perhaps by a 'trusted' third party.  A final, more subtle exchange of data, is that the service provider now clearly knows you are looking for new insurance / moving house / selling your car.  That is quite a powerful personal context to each of those scenarios.

Is The Exchange of Information Worth It?

This is obviously a subjective question as the information you exchange will have a different value to each data owner.  You could argue that personal contact information is pretty much public domain anyway.  They have been Yellow Page equivalents and directory enquiries facilities for decades.

Finding someones personal or work email address is also pretty trivial these days, simply as they are so commonly used to sign up to so many services.  Many also will take the view, that if someone does send you a marketing or spam email, your ISP filters will simply place it into a junk folder and no harm is done.

If in return, you receive a free white paper, document, quote, temporary access to a new service, or signup to a freemium product perhaps giving away some personal contact information is a good deal?

However, what happens to the data that is harvested?  Where does it end up?  Contact information is one thing, but adding in additional details such as your personal circumstances, how many people live in your property if it's for an insurance quote for example, or perhaps releasing your mobile number, could result in future impacts on your privacy.

Is There An Impact On Privacy?

Again this could be a subjective answer.  There have been many discussions in the past 36 months regarding government surveillance of both individuals and government officials.  I am not an advocate for or against surveillance, but was there a physical impact on the individual during the snooping?  Note the word during.  Many people talked about the invasion of privacy and human rights, but that was only after they knew they had been observed.  The reaction was generally a retrospective one, not an active one.  That is not to say it's less valid, but the context needs to be applied.  The same could be said regarding commercial use of personal data. It's all good, until it isn't.  Whilst no one uses your personal data maliciously, is there a problem to address?  This can probably be classified in the same file as the infamous 'unknown unknowns' approach to threat intelligence by the US government.

eCommerce, Digitization and 'Sticky' Customers

Many organizations have no interest in using personal data maliciously.  The increased digitization of previously physical services and the increased use of online retail, has lead many organizations trying to get a better picture of their consumers, customers and potential customers.  Note the subtle difference between a consumer (who is actively using a service perhaps without registration eg Google), a customer (paying for a service or good) and potential customer.  All have different characteristics from a marketing and customer servicing perspective.  A organisation wants to get the individual perhaps down a consumer --> customer --> repeat/upselling customer route as quickly as possibly, but with a stickiness towards the latter part of the journey - ie when they're a customer keep hold of them.

The information exchange at the beginning of that cycle is key to helping organisations follow that flow.  From a individuals perspective, there needs to be a strong service improvement or cost saving aspect in order to sacrifice some of the data that is being asked for.

By Simon Moffatt