The deployment of strong authentication procedures adds greater operational complexity to the classical means of interaction with customers and here, once again, given that the situation may entail a certain level of initial confusion, it would be advisable to develop educational and assistance programmes that help accommodate users to the new reality. Bank customers and financial education I cannot stress this point enough. Financial and digital literacy are basic, crucial factors for the efficient use of financial technology and for lessening the level of risk implicit in its use. Involuntary authorisation for access to personal information or fraud, to which I have just referred, are merely some of the examples of this implicit risk. Other examples are: (i) the offering of complex, opaque projects that are difficult to understand and which may be wrapped up in a user-friendly fashion for the public at large through applications (apps or similar); (ii) the disclosure of relevant information, pre-contractual or contractual alike, through smart phones or tablets, in which the size of the screen and the immediacy of acceptance limit customers’ capacity to know what they are really agreeing to; (iii) limitations in obtaining direct and personalised advice from a qualified adviser; (iv) discrimination linked to the use of macro-data, in the sense that the use and knowledge of personal data by 6/8  services providers might result in discriminatory practices against specific groups of consumers, normally those who are most vulnerable; and (v) the risk of financial exclusion linked to the lack of digital skills.

Subjects under analysis are, for instance, the implications of the provisions of the new Directive on payment services, known as PSD2, whose partial transposition in Spain is imminent, under the Government’s Annual Regulatory Plan, and to which I shall shortly refer. And there are also other topical matters, such as distributed ledger technology, “cloud” computing and the phenomenon of sovereign digital currencies. 3/8  Against this backdrop, the aim of my address is to offer some observations as to how the new technologies are changing the traditional bank-customer relationship, and to highlight the need for banks and customers to responsibly manage this new scenario. Likewise, I wish to stress the importance of financial education in this new scenario. Customers have more options, but also more responsibility, and it is essential they should be aware of this. Returning to the origins of the concern for the rights of bank customers. To set these observations in perspective, we might recall that concern in Spain to safeguard customer rights arose in the 1980s, as a consequence of the liberalisation the industry underwent and which enshrined freedom of contract – of interest rates and commissions – at the core of its workings. Accompanying this process, legislators adopted a series of measures aimed at boosting competition among banks, including most notably the enhanced comparative information with which banks must provide their customers, so that they may know the content of their rights and obligations before and once they have given their consent.