Project Overview
A UK FinTech startup wanted to build a credit score improvement app — showing UK consumers their credit score ...
Technology Stack
Compliance & Standards
The Challenge
A UK FinTech startup wanted to build a credit score improvement app — showing UK consumers their credit score (Experian, Equifax, TransUnion), explaining the factors affecting it, and providing personalised recommendations to improve it. FCA Consumer Duty (financial promotions via the app), ICO UK GDPR for credit data, FCA COBS 4 (clear, fair and not misleading for financial guidance vs advice), and the Credit Reporting Act implications were the requirements. Budget: £85,000.
Our Approach
UK Credit Bureau API Integration
Experian ConsumerView API (UK): soft credit search (no credit file impact), credit score (0–999 Experian scale), credit summary data (accounts, payment history, credit utilisation).
Equifax Consumer API
Equifax Credit Score (0–700 UK scale), payment history, open accounts.
TransUnion UK
- equivalent data.
- Multi-bureau: ClickMasters built a normalised score model (composite 0–100) from all three bureaux — more accurate than any single bureau.
Consent
explicit UK GDPR consent for credit bureau access, refreshed annually.
Recommendation engine
rule-based (not ML — FCA Article 22 automated decision-making compliance simpler for rule-based).
Rules
- electoral roll not registered → "Register to vote — could improve your score by X points", utilisation >
- 30% → "Pay down credit card to below 30% utilisation", missed payments → "Set up direct debit for minimum payment", no credit history → "Consider credit builder card".
Each recommendation
- estimated score impact, effort level (easy/medium/hard), and steps.
- FCA Consumer Duty —
FCA COBS 9
giving personalised recommendations about specific financial products (e.g., "you should take credit card X") requires FCA authorisation as an investment adviser or credit broker.
FCA Consumer Duty guidance
- explaining credit mechanics and recommending generic actions (register to vote, reduce utilisation) does not constitute regulated financial advice.
- The app avoids all specific product recommendations — it explains factors and actions, not products.
UK GDPR Credit Data Handling
Credit data is highly sensitive personal data (not special category, but high sensitivity ICO guidance).
Basis
explicit consent (Article 6(1)(a) — freely given, specific, informed, unambiguous).
Retention
score data retained for 12 months, deleted on account closure.
Right to erasure
all bureau API data deleted within 24 hours of erasure request.
Data breach
credit data breach reportable to ICO within 72 hours (high risk to individuals).
The Results
App launched iOS and Android at 12 weeks, £78,000 — under budget.
Users: 34,000 registered in first 6 months (organic).
Average score improvement (users following 3+ recommendations in 6 months): +48 points (Experian scale).
Recommendation acceptance rate: 62%.
App Store rating: 4.6/5.
FCA Consumer Duty: legal review confirmed no regulated financial advice being provided.
ICO GDPR audit: consent mechanism and data handling confirmed compliant.
“48 point average score improvement for users who followed 3+ recommendations. That is a material change in someone's financial life — mortgage eligibility, credit card rates, phone contracts. 34,000 organic users in 6 months validated the product. The FCA COBS 4 guidance vs advice boundary was the hardest decision — getting that right defined the product." — CEO, UK Credit Score FinTech (name withheld)”
Project Details
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