AS THE COMMERCIAL USE OF PERSONAL DATA GROWS exponentially, so do concerns over whether that data will be used in consumers’ best interests. This is particularly true for financial services in emerging economies, where data expand the potential for reaching poor and underserved communities with suitable products but where customer protection risks are great. In many markets ranging from Indonesia to India and Kenya, it is unfair to impose the burden of consent on individuals to protect their data when such a large proportion of the population are opening accounts or coming online for the first time, literacy rates are low, and individuals face potential language and technological barriers.