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.
Naavi
February 8, 2011
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naavi@vsnl.com
Copy
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