Pilot proposals

Databanking pilots

Each proposed pilot focuses on a single jurisdiction and class of transaction, with a closed group of participants large enough to test whether the technical architecture, institutional model, market mechanisms and regulatory treatment can work together in practice. The pilots follow a common framework to allow meaningful comparison of their results, while building on the existing capabilities and arrangements of each jurisdiction.

Scotland · UK law

A Scottish Databanking pilot

A bounded demonstrator of regulated personal-data intermediation: one sector, one class of transaction, and a closed initial ecosystem of individuals, data providers and relying organisations assembled for the purpose. The aim is to determine whether Scotland can serve as an incubator for a new regulated data-infrastructure model.

Can Scotland demonstrate, in one carefully selected domain, that valuable decisions can be made using personal data without requiring the organisations making those decisions to possess the underlying personal record?

Estonia · EU law

An Estonian Databanking pilot

A bounded demonstrator built on infrastructure Estonia already operates: X-Road, strong electronic identity, the consent service and the Data Tracker. One transfer of state-held data to private companies is replaced by a query to a licensed custodian of the person's choosing, with credit affordability as the lead use case.

Can Estonia demonstrate, on infrastructure it already operates, that a lender can make a lawful credit decision based on an answer instead of a record, where the record is held by an independent custodian that the prospective borrower chose and can change?

Vermont · US state law

A Vermont Databanking pilot

A bounded demonstrator under laws Vermont has already enacted: a licence for personal-data custodians with a fiduciary duty, a statutory standard of proportionate collection, and rules on privacy-minded age assurance. Age checks are answered by a licensed custodian of the person's choosing instead of an identity document.

Can Vermont demonstrate, under laws it has already enacted, that a business can establish a person's age from a one-bit answer instead of an identity document, where the record is held by an independent custodian, licensed by the state, that the person chose and can change?

What they share

Four forms of viability

All three pilots are judged against the same four questions. The constituent technologies largely exist, so the more difficult questions are institutional and economic.

1

Technical

Can a Databank derive and release useful information while preventing disclosure of the data underneath it?

2

Institutional

Can an independent custodian hold a credible structural separation between custody and exploitation?

3

Market

Will individuals use such an intermediary, and will organisations accept a constrained output in place of the raw information?

4

Regulatory

Can Databank outputs, controls and accountability mechanisms be made robust enough to be treated as trustworthy?

The same four roles

All three pilots model the same ecosystem, with explicit responsibilities and liability boundaries between its participants.

  1. 1
    The individualAuthorises the use of their information, and whose interests the custodial framework exists to protect.
  2. 2
    The authoritative data providerSupplies or verifies the underlying information from which answers are derived.
  3. 3
    The DatabankMaintains custody, identity binding, policy enforcement, computation, auditing and controlled disclosure.
  4. 4
    The relying organisationSubmits an authorised query and accepts the resulting output instead of the underlying record.

Regulators and independent auditors sit above these four as a governance layer.

The same research programme and the same test

Nine research questions run through all three proposals: query leakage, computation scrutiny, correctness and provenance, identity binding, liability and dispute resolution, coercive authorisation, concentration and resilience, interoperability and portability, and economic sustainability. The Estonian proposal adds a tenth, audit visibility, which the Data Tracker makes measurable, and the Vermont proposal adds fiduciary custody, which Vermont's licence for personal information protection companies makes testable. Several are open research strands in their own right.

All three start from a closed initial ecosystem rather than a public launch, and proceed through the same five phases, from scoping and consortium formation to an evidence-based expansion decision. All are judged by the same three propositions: individuals entrust the data to the custodian, relying organisations accept the minimal output instead of the record, and the custodian is economically sustainable while remaining independent of commercial exploitation of what it holds.

Where they differ

Three starting points

The Scottish pilot assembles a closed network inside UK law. The Estonian pilot adds the custodial layer to infrastructure Estonia already runs, inside EU law, and concentrates on the parts of the model that no existing system tests. The Vermont pilot uses a custodian licence already in state statute, under new state privacy laws and in the absence of a general federal privacy statute.

ScotlandEstoniaVermont
Legal settingUK lawEU law, including the GDPR, the Data Governance Act, the European Digital Identity framework and the Consumer Credit DirectiveVermont law, including the licence for personal information protection companies, the Data Privacy and Online Surveillance Act and the Age-Appropriate Design Code, with no general federal privacy statute
Starting pointA closed initial network of individuals, data providers and relying organisations, assembled for the pilotInfrastructure already in production: X-Road, strong electronic identity, the consent service and the Data TrackerA custodian licence in statute since 2018, and new privacy laws taking effect in 2027 and 2028
What the pilot addsThe ecosystem as a whole: the custodian, and agreements with the data providers and relying organisations that use itAn independent custodian, competition between two custodians, account portability and the person's share of each access feeThe Databanking conditions on a licensed custodian, competition between two custodians, account portability and the person's share of each access fee
CustodiansOne Databank, with multiple interoperable Databanks as the longer-term directionTwo Databanks from the start, so that choice and switching can be observedTwo Databanks from the start, each licensed by the Department of Financial Regulation
Lead use caseSelected jointly with participants; candidates include age and identity verification, financial eligibility, professional credentials and health informationAffordability for consumer credit, using Tax and Customs Board income recordsAge assurance, with 21 or over as the running example, using motor vehicle records
EmphasisAll four forms of viability at onceInstitutional and market viability, since existing infrastructure settles most of the technical questionInstitutional, market and regulatory viability, under statutes already enacted
Audit visibilityAn audit framework designed within the pilotEvery query shown to the person on eesti.ee through the Data TrackerEvery query shown on the person's account statement
What it would take to startA small interdisciplinary group to identify the strongest Scottish use case and the institutional and funding structureA scoping meeting with the Estonian authorities, access to the X-Road test environment and the Data Tracker, a supervisory contact, and four requests of the European CommissionA scoping meeting with the Vermont authorities, licence applications to the Department of Financial Regulation, an Attorney General's Office contact on age assurance, verification by the Department of Motor Vehicles, and a briefing for the legislative committees

Run together

Pilots under different legal regimes would also test whether accounts and attestations can move across borders, between custodians regulated in different jurisdictions. That question decides whether Databanking becomes international infrastructure or remains a national scheme.

Further pilot proposals will be listed here as they are prepared. The model itself is set out in the Databanking whitepaper, and the FAQ addresses the objections it most often meets. Enquiries about hosting or joining a pilot are welcome at contact@databanking.org.

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