Front Matter

Title page


Toward a Global Approach to Data in the Digital Age

Vikram Haksar, Yan Carrière-Swallow, Andrew Giddings, Emran Islam, Kathleen Kao, Emanuel Kopp, and Gabriel Quirós-Romero


2021 October

Copyright Page

©2021 International Monetary Fund

Toward a Global Approach to Data in the Digital Age


Prepared by Vikram Haksar, Yan Carrière-Swallow, Andrew Giddings, Emran Islam, Kathleen Kao,

Emanuel Kopp, and Gabriel Quirós-Romero1

DISCLAIMER: Staff Discussion Notes (SDNs) showcase policy-related analysis and research being developed by IMF staff members and are published to elicit comments and to encourage debate. The views expressed in Staff Discussion Notes are those of the author(s) and do not necessarily represent the views of the IMF, its Executive Board, or IMF management.

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  • A. The Value of Data and Who Should Derive It

  • B. Privacy and the Digital Economy


  • A. Data and Efficiency in Financial Services

  • B. Data Resilience in Financial Services

  • C. Data and Discrimination in Financial Services



  • A. Towards Global Data Policy Frameworks


  • BOX

  • 1. Key Elements of Common Minimum International Principles






  • 1. Big Tech Market Capitalization

  • 2. Decomposition of Markup Increases in the Tech Industry

  • 3. Explained Credit Scores (area under curve) with Different Models

  • 4. Cybersecurity and Data Breaches

  • 5. Global Trade in Data-Driven Services

Executive Summary

Ongoing economic and financial digitalization is making individual data a key input and source of value for companies across sectors, from Big Tech and pharmaceuticals to manufacturers and financial services providers. Data on human behavior and choices—our “likes,” purchase patterns, locations, social activities, biometrics, and financing choices—are being generated, collected, stored, and processed at an unprecedented scale.

Use of individual data and digital innovation can power productivity; increase access to finance; and promote trade, including of digital services, to the benefit of all. Inspired by the Bali Fintech Agenda (IMF 2018b), this Staff Discussion Note argues that the rules and regulations governing access to this individual data are emerging as a new pillar of structural policies that matter for growth, equity, and financial stability. This imperative is recognized by the G7 Panel on Economic Resilience in its June 2021 statement. The data policy frameworks are being reviewed around the world to strike a balance between privacy and societal needs on one hand and economic and financial benefits on the other, albeit from a mostly national or regional perspective. Key challenges include the following:

  • Balancing privacy trade-offs: Policies to protect privacy—an important objective in most countries— can mitigate the undesired use of individual data. But protecting privacy can impede private and public efforts to generate economic and social gains from access to data and its use in support of regulatory enforcement and the fight against criminal activity. Clear rules are needed to tackle these trade-offs, including giving people effective control over their data.

  • Promoting inclusive digitalization: Data can support greater efficiency and inclusion, including in the provision of financial services. But it can also be used for price discrimination and may feed algorithmic biases, disadvantaging and excluding some individuals from important services.

  • Fostering competition in the digital economy: Individual data as a resource can support productivity, enhancing innovation and the public good—such as for biomedical research. But it can be hoarded by large data collectors, reducing competition, which could dampen innovation and raise financial stability risks.

Domestically, new policy tools and approaches are being considered to provide solutions to these challenges, including mandates for interoperability of networks and data portability, creation of data fiduciaries to help manage consent to protect privacy, and public data utilities to provide data as a public good while protecting privacy. Balancing trade-offs between objectives and the integration of specific policy solutions will require unprecedented cooperation among regulators and government agencies with individual mandates for policies and outcomes on competition, financial stability, integrity, consumer protection, and privacy. Promoting biomedical research may call for greater data sharing, but could conflict with privacy. Increasing competition in financial services could expand the perimeter of service providers, challenging integrity and stability.

Internationally, cooperation is critical to contain fragmentation of the global digital economy, which could harm developing economies in particular through the emergence of a digital and data availability divide. Data is the ultimate mobile factor, with cross-border data flows underpinning a rapidly growing proportion of international services trade. But this note argues that the data policies countries are adopting are not always consistent with global welfare. Countries’ treatment of privacy, competition, and stability reflects national priorities. The resulting fragmentation could be damaging to smaller countries with smaller data pools and those more dependent on multinational foreign digital firms.

This note argues for development of international agreement on common minimum principles for the data economy. These principles could reduce policy divergences that will arise in the global digital economy, in part reflecting different national contexts and priorities. For example, individual countries may place different emphasis on privacy, but a common understanding of definitions and perimeters of applicability of privacy protection mandates could mitigate avoidable divergences. Many of the other domestic policy approaches being proposed for managing the data economy—for example, on interoperability and data portability to address competition or on the introduction of data fiduciaries to manage consent—could also benefit from common principles on their international application. Likewise, there is scope for international coordination on compilation and sharing of data sources from private digital companies—for regulatory and public policy purposes—including as recognized by the Group of Twenty (G20) ministers in their July 2021 call for a renewed Data Gaps Initiative.

While there is significant uncertainty about how the digital economy will evolve, a global approach will be needed to ensure a level digital playing field for all countries increasingly connected to and dependent on the digital economy. Such an approach will help the digital economy generate value for all without undermining other important macro-financial and social objectives.

Key Elements of Common Minimum International Principles

  • Principles for data protection: An international agreement on common minimum standards for acceptable protection of individual data when it is shared across borders would reduce uncertainty for businesses seeking to comply. Such an approach could draw on the OECD Principles on Privacy (1980 and amended 2013), with further thought on issues such as the role of consent and the definition of data and individuals.

  • Principles on interoperability and data portability: Given the global reach of businesses that make use of individual data as an important part of their business, there is a need to discuss common principles on how such interoperability and portability should work across borders (Furman and others 2019). Specific use cases include cross-border payments and cross-border data sharing across open banking initiatives (Committee on Payments and Market Infrastructures 2020). A concrete challenge is to coordinate on principles for enabling the interoperability of digital currencies issued by central banks when these can be used across borders, including a method for digitally identifying individuals and standards for digital wallets and data flows.

  • Principles on data sharing for regulatory purposes: A rigorous data framework should govern not only the protection of data, but also its disclosure to public bodies, including regulatory authorities, where necessary to meet certain public policy objectives. Exemptions to confidentiality and secrecy provisions are already commonplace in many national frameworks (for instance, tax law and anti–money laundering and combating the financing of terrorism) and in line with many international standards and best practices (such as Financial Action Task Force standards and Organisation for Economic Co-operation and Development tax initiatives). Carefully balancing privacy concerns against disclosure for public policy objectives continues to be needed as data regimes evolve. In line with current efforts, and to the extent possible, principles on data disclosure to public authorities should aim to achieve common ground across national frameworks to allow for global data sharing for enforcement or regulatory purposes.


We are very grateful for guidance from Aditya Narain, Yan Liu, and Martin Cihak; for substantial contributions from Barend Jansen and Ghiath Shabsigh; and for valuable comments from Maria Soledad Martinez Peria, Nicola Pierri, Florian Gimbel, and other colleagues from IMF departments. We are also thankful to Pavel Lukyantsau, Ashley Abraham, and Lilly Siblesz de Doldan for research and production support.

Toward a Global Approach to Data in the Digital Age
Author: Mr. Vikram Haksar, Mr. Yan Carriere-Swallow, Emran Islam, Andrew Giddings, Kathleen Kao, Emanuel Kopp, and Gabriel Quiros