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G Gopalakrishna Working Group (GGWG) on Electronic Banking

Comments-on Consumer Education Issues

Chapter VIII of the GGWG deals with Consumer Education. In stark contrast to the chapter on Legal issues, the Chapter VIII of the working group reflects a very professional approach to the needs of Consumer Education.The Sub Commitee which worked on this aspect has provided several useful suggestions for banks to follow. Hopefully RBI endorses the recommendation in full

The group has made 10 suggestions as discussed below.

1.Need For Commitement:

The GGWG has rightly placed emphasis on the commitment from the Board and Senior Management towards process of consumer education initiateives by providing adequate erwources, ealuating the effectiveness of the process, fine tuning and improving the customer education on an ongoing basis.

2. Organizational Structure

The GGWG recommends that the bank should identify the key stake holders in decision making, planning, implementation and evaluation. It has given a recommended plan of action involving establishing a working group, defining the target groups, identifying solutions etc.

3. GGWG recommends a systematic process of development of an awareness program.

4.GGWG suggests development of customized awareness programmes for Bank Customers, Employees, Law Enforcement Personnel, Fraud Risk Professional, media partners etc.

5. GGWG suggests building of a consensus amongst decision makers and stakeholders.

6. GGWG has also suggested development of a communiction plan to reach out the IS message to all stake holders through various channels.

7. GGWG recommends formation of a Research Group to continually update the communication group with the information that needs to be communicated to different target groups.

8. GGWG recommends measurement of the effect of communication campaigns through tested evaluation techniques such as Focus Groups, Interveiws etc.

9. GGWG also recommends customer training programmes when new technologies are introduced

10. To support all the activities, the GGWG recommends development of a documented policy.

It can be seen from the above that the recommendations of the Working group in Customer Education is very comprehensive and systematic. Banks who are presently following adhoc measures just to be seen as doing something in this direction need to spend lot more management time in conceiving an appropriate plan of action.

Naavi.org suggests that as a part of the implementation, every  Branch should form an "Information Security Watch Group" (ISWG) consisting of the Staff members and a few Customers. The Customers should not be selected just to complete the formality but with  a sense of purpose. Volunteers from the Customers can be invited.

ISMGs at each branch should be able to communicate with other counterparts within the Bank and share intelligence.

At the Bank's level, an ISMG Coordination Committee should be formed which may interact with ISMG coordination committees of other Banks to develop an Industry level coordination which would be highly useful in fraud prevention.

The standing committee of RBI which has been recommended to follow up the GGWG recomendation can interact with the ISMG coordination Committees of different Banks so that there will an industry level infrastructure for IS which involves the Banks, the Customer and the Regulator.

Unless RBI takes a suitable follow up action, the recommendation under this chapter would be overlooked by Banks and substituted by a few half page news paper advertisements which can be show cased.

The requirements suggested under this chapter should be specially coordinated by the Head of the Training division in the Bank in close coordination with a professional full service advertising agency which has the necessary communication and research service facilities.



February 8, 2011

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Copy of Full Report of GGWG

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