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Monzo’s Outdated Verification Methods: A Critical Analysis

This article critically examines Monzo’s seemingly outdated verification methods—requesting ID selfies via unencrypted email and obscure phone quizzes about forgotten “pots.” Despite presenting as a leading digital bank, these practices raise serious GDPR security concerns, frustrate legitimate customers, and potentially conflict with the FCA’s Consumer Duty. The piece outlines regulatory implications  and user reactions for Monzo inadequate security mechanisms and dismissive cancelled culture. 

EXAMINING MONZO'S INSECURE EMAIL REQUESTS

Monzo’s Outdated Verification Methods: A Critical Analysis

Monzo, widely regarded as an innovative “challenger bank,” rose to prominence by offering real-time payments, budgeting tools (like “pots”), and a user-friendly mobile application. Historically, its technology-driven ethos and transparent marketing set it apart from traditional high-street banks. However, emerging accounts of outdated, insecure, or customer-unfriendly verification processes create a dissonance between Monzo’s self-portrayal and its actual practices. These issues include:


1.1.     Unencrypted Email Requests: 

  • Users are asked to send highly sensitive identity documents (selfies with ID) via standard email—a notoriously insecure channel that can expose data to interception or misuse.


1.2.     Obscure Phone Questions: 

  • Phone representatives asking about long-forgotten “pots” or details from years ago, with no flexible alternatives, forcing legitimate customers to “fail” security if they cannot recall trivial account history.


1.3.     Rigid and Unhelpful Service: 

  • Anecdotes of abrupt call terminations or refusal to proceed when a user cannot satisfy a single obscure question. This leaves genuine customers locked out, fostering distrust.


  • Such problems not only conflict with Monzo’s self-image of a digitally sophisticated operation but also risk contravening regulatory standards—notably, data security requirements under UK GDPR and fairness principles under the FCA Consumer Duty. For a bank priding itself on “the future of finance,” these are glaring oversights. Critics argue that if a supposedly high-tech bank continues pushing insecure email for sensitive data, it raises questions about whether it is “running with other people’s money” like a band of pirates rather than protecting customers as promised.


  • This report provides an extensive analysis of these issues, their regulatory implications, consumer reactions, and recommended reforms to realign Monzo’s practices with both public expectations and fundamental data protection obligations.


2.     Introduction: Monzo’s Contradictory Reputation


  • Monzo launched with a flurry of positive press and was one of the first UK fintechs to offer:


2.1.     Instant Notifications: 

  • Real-time spending updates on smartphones.


2.2.     Fee-Free Spending Abroad: 

  • Early marketing campaigns touted minimal foreign exchange fees.


2.3.     Pots for Budgeting: 

  • Quick sub-accounts to separate funds for savings, bills, or specific goals.


2.4.     Transparent, Customer-Centric Branding: 

  • A modern approach that championed openness, big on “We’re not like your old bank.”


  • For years, this approach helped Monzo develop a near-cult following among younger consumers and tech enthusiasts. Many hailed it as a revolutionary “app-based bank” that put the old banking system to shame. 


  • Yet, recent accounts suggest that behind the polished user interface, some of Monzo’s day-to-day operational practices remain stuck in the past—particularly when it comes to identity verification and dispute resolution. 


  • These contradictions are at odds with the tagline of being a “digital-first” institution. Instead, the critics claim, Monzo sometimes behaves like an old-fashioned operation using outdated or insecure channels, effectively “pulling the rug out” from customers when they need help the most.


3.     Verification via Email: The Core Security Flaw


3.1.     The Practice: Emailing Selfies with ID

  • Multiple users report being asked by Monzo to send a selfie of themselves holding their ID—like a passport or driver’s license—through unencrypted, plain-text email. 


  • This tends to occur when:
    • A user is locked out of the Monzo app (e.g., after losing or changing phone).
    • Monzo flags a suspicious transaction or needs extra checks.
    • The user is trying to retrieve old statements or complete a request (such as a Subject Access Request under GDPR).


  • Rather than providing a secure upload portal or in-app verification (as is done initially when opening an account), Monzo staff direct users to standard email. 
  • Since email is typically unencrypted, it is an insecure channel that can be intercepted or compromised, placing personal data at substantial risk.


3.2.     Why This is Risky


3.2.1.      Exposure to Interception

  • Plain email traffic can be intercepted by malicious parties, especially on public Wi-Fi or compromised networks. If an attacker gains access, they can harvest passport numbers, addresses, birthdates, and facial images—enough to commit identity fraud.


3.2.2.     GDPR Requirements

  • Under the UK General Data Protection Regulation (UK GDPR), personal data (especially ID documents) must be processed securely, requiring “appropriate technical or organizational measures.” 
  • Article 5(1)(f) specifically compels companies to uphold integrity and confidentiality. 
  • Email attachments containing passports or licenses, in many experts’ opinions, fail the “appropriate security” test unless encrypted.


3.2.3.     Data Breach Liability

  • A data breach involving unencrypted ID documents could trigger heavy fines from the UK’s Information Commissioner’s Office (ICO). 
  • Past cases (e.g., major fines against companies for insufficient encryption) illustrate how regulators penalize entities that handle personal data negligently.


3.2.4.     Inconsistent with Tech-Savvy Image

  • Monzo touts cutting-edge tech. Encouraging email-based identity checks directly contradicts the advanced security stance the bank claims. 
  • Traditional banks have long avoided advising customers to email ID documents unencrypted, so it appears especially outdated for a self-branded “digital pioneer.”


3.3.     Customer Alarm

  • Unsurprisingly, many loyal Monzo customers, who typically trust the app-based approach, feel unsettled or suspect a scam when they receive these instructions. 
  • They question whether the request is legitimate, leading to confusion and a breakdown in trust. 
  • The practice has been publicly lambasted on forums and social media, with critics calling it “pirate-like” data handling—akin to “stealing” personal info or at least exposing it to risk. It shatters the expectation that “digital bank” equals “secure by design.”


4.     Phone Verification: Rigid Questions and Unhelpful Calls


4.1.     Obscure “Pots” and Historical Trivia

  • Monzo’s “pots” feature is a popular tool for short-term savings or budgeting sub-accounts. Some accounts date back to 2016–2018 when pots could be automatically generated (for instance, via salary-splitting). 
  • Customers have reported being quizzed about the exact name of their first pot from years ago to pass phone verification. If they cannot remember or never consciously created the pot themselves, they “fail” verification.
  • This approach is seen as unnecessarily obscure. The pot name is not a standard security question (like mother’s maiden name or a memorable word).
  •  It feels more like an internal detail that might not be commonly known to the account owner—especially if the pot was auto-created or used only fleetingly.


4.2.     Surprise Calls and Early Timing

  • Customers also mention receiving calls at times that don’t match the scheduled slot (e.g., an hour early), leaving them unprepared:
  • They might not have immediate access to old statements or pot history.
  • The representative apparently offers no alternative if the user says, “I can’t recall that pot name.”
  • In some cases, calls ended abruptly, with the user told, “You failed security,” and no further help was provided.


4.3.     Possible Breach of FCA Standards

  • The Financial Conduct Authority (FCA) has a framework for fair treatment of customers and efficient complaint resolution. A crucial concept is Consumer Duty, requiring banks to provide good outcomes for customers by being clear and not erecting unfair barriers. For instance:
    • 4.3.1. DISP 1.4.1 R (FCA Handbook) instructs firms to handle inquiries “fairly, consistently and promptly.” Rigid phone checks about pot names from years back—without a fallback method—could be viewed as unfair. It may block genuine customers from their own accounts.
    • 4.3.2. The Consumer Duty also emphasizes empathy: if a user is in a stressful situation (locked out of funds), the bank should not force them into a memory test that’s prone to failure. Doing so undermines customer welfare.


4.4.     Impact on Customer Trust

  • It’s one thing to have robust security measures; it’s another to appear to be “catching out” legitimate customers who simply cannot recall a random pot name from half a decade ago. 
  • The phone-based verification process, when combined with abrupt endings and no second chances, feels less like a protective measure and more like an institutional hurdle. 
  • Users have described it as “pirate-level,” in the sense that they were effectively “boarded, questioned abruptly, and left adrift without explanation.”


5.     Regulatory and Compliance Overview


5.1.     UK GDPR

  • 5.1.1. Article 5(1)(f): 
    • Requires data to be processed securely. Sending passports or IDs via unencrypted email undermines confidentiality.
  • 5.1.2. Article 32: 
    • Mandates “appropriate technical and organizational measures” such as encryption at rest and in transit, especially for sensitive data (like government-issued IDs). 
  • A simple email attachment is a widely known vulnerability, placing Monzo’s policy in questionable territory.
  • A regulator could argue Monzo is not “taking all steps to ensure data security,” opening the door to potential enforcement action or fines if user data is compromised.


5.2.     FCA Consumer Duty and Complaints Handling

  • 5.2.1.  Consumer Duty: 
    • Banks must ensure the best possible outcome for customers, not just meet a minimal standard of security. 
    • Overly complex or archaic methods can cause “foreseeable harm” to legitimate customers, which the Duty aims to prevent.
  • 5.2.2. Fair Treatment of Customers (TCF): 
    • This principle demands that processes do not unfairly exclude or disadvantage people. 
    • ]Expecting them to recall years-old pot names or sending sensitive info via insecure channels arguably disadvantages them.
  • 5.2.3. DISP 1.4.1 R:
    •  If the user is raising a complaint or is in the midst of an account closure/issue, the bank must handle it fairly and promptly. 
    • Relying on outdated security checks can hamper the resolution timeline and create additional distress.


5.3.     Potential Consequences

  • 5.3.1.  Reputational Risk: 
    • Even if regulators do not formally sanction Monzo, widespread complaints and negative social media coverage erode brand trust.
  • 5.3.2. Financial Penalties: 
    • Should there be a breach or a large volume of complaints, the FCA could impose sanctions. 
    • The ICO could impose fines if Monzo fails to protect personal data.
  • 5.3.3. Customer Attrition: 
    • Customers may close accounts if they perceive that Monzo’s verification or security standards are dangerously lax or unfairly obstructive.


6.     Consumer Feedback and Public Perception


6.1.     Online Forums and Social Media

  • Monzo’s community forum once showcased enthusiastic posts praising the bank’s “new wave” approach. Lately, threads highlight:
    • 6.1.1.  Shock at Email Practice
    • 6.1.2. Users comment that “no reputable bank” would request passports over plain email.
    • 6.1.3. Others share they initially assumed it was a phishing attempt—only to discover it was legitimate.


6.2.     Frustration over Pot-Related Quizzes

  • Comments describing phone calls where the user was asked about the pot name from 2018.
  • Many claim they had never personally created or named a pot, so they felt set up to fail.


6.3.     Erosion of Trust

  • Some long-term fans say they’re reconsidering if Monzo is truly “cutting-edge.”
  • The phrase “feels like being left high and dry by pirates” arises in a few rants—a metaphor for an institution that takes your money but leaves you on your own when verifying identity or reclaiming funds.


6.4.     Media and Competitor Banks

  • Several fintech review sites and consumer advice columns have picked up on these complaints. 
  • There is growing commentary that “Monzo’s polished app UI masks older back-end practices,” suggesting that the bank’s public-facing brand might be more advanced than its operational reality. 
  • Competing digital banks highlight their own secure, in-app document upload features as a direct contrast, implying that Monzo’s approach is behind the times.


7.     Criticisms: “Old-Fashioned Waze” vs. Tech Claims

  • Monzo’s marketing typically revolves around a forward-thinking approach—no branches, no legacy systems. 
  • Yet these specific verification methods resemble:
    • 7.1.      Manual Email Exchanges—like a decades-old process predating advanced encryption.
    • 7.2.     Arcane Call Quizzes—akin to older phone-banking models that ask customers random questions from account history.
    • 7.3.     Deflections and Abrupt Endings—something many associate with poorly trained call center staff, reminiscent of older, less agile institutions.
  • This discrepancy angers users who believed Monzo’s hype about being “the future of banking.” 
  • Instead, they see a mismatch so jarring that they label it “bullshit” and accuse the bank of operating like “pirates”—collecting user data in insecure ways, then failing to assist when customers truly need service. 
  • The frustration stems from the gap: 
  • if Monzo truly were a best-in-class digital bank, why is it not using standard secure channels or more user-friendly knowledge checks?


8.     Recommendations for Improvement

  • To address these criticisms and align with genuine digital standards, Monzo should:


8.1.     Overhaul Email Verification

  • 8.1.1.     Implement Secure Upload Portals
    • Provide a unique, end-to-end encrypted link for users to upload ID documents.
    • Time-limited links that automatically expire reduce risk.
    • This is a common industry practice—far safer than attachments in plaintext email.
  • 8.1.2.     Offer Alternate Channels
    • If the app is inaccessible, allow a password-protected PDF or document with the password sent via SMS/call.
    • Integrate an “Emergency Verification” feature within a website or a separate support app to avoid regular email.
  • 8.1.3.     Educate Staff and Customers
    • Enforce a policy: “Never request unencrypted ID docs via standard email.”
    • Update help guides so customers know they have secure alternatives.


8.2.     Streamline Phone Verification

  • 8.2.1.     Use Universal Security Checks
    • Rely on recent transactions, address confirmation, a passcode or code texted to the user, or partial ID info.
    • Avoid obscure questions about pot names or other rarely-used features from years ago.
  • 8.2.2.     Multiple Methods for Failing One Check
    • If the user can’t confirm one detail, offer a second or third question.
    • Provide a fail-safe route, such as “We’ll send a one-time code to your phone or email on file.”
  • 8.2.3.     Schedule Calls or Provide Call-Backs
    • Let the customer pick a time, so they can gather relevant info.
    • If a call is missed, allow an easy way to request a new slot without penalty.


8.3.     Bolster Consumer Duty Compliance

  • 8.3.1.     Vulnerability Protocol
    • If a customer is older, disabled, or stressed, staff should pivot to a more flexible approach.
    • Document that staff must not automatically terminate calls if the first piece of info is incorrect.
  • 8.3.2.     Transparency in Complaint Handling
    • Clarify how identity will be verified for complaints or account closure disputes.
    • Provide estimated timelines and escalate promptly if standard verification fails rather than leaving customers in limbo.


8.4.     Publicly Reassure and Recommit

  • 8.4.1.     Publish a Security Statement
    • Outline specific steps being taken to adopt secure verification.
    • Affirm that plain email is no longer used for ID checks.
  • 8.4.2.     Solicit User Feedback
    • Invite user suggestions on phone verification. Possibly run a pilot program with a different set of security questions and gather data on success rates.
  • 8.4.3.     Leverage Monzo’s Strengths
    • Integrate more advanced in-app features: 
    • Video calls with embedded ID scan, user-driven re-verification via app with multi-factor authentication, etc.
    • Show the community that Monzo truly stands by its technology-forward identity.


  • By implementing these measures, Monzo can address the fundamental criticisms—that it appears ironically “low-tech” or even “reckless” in verifying user identity—while fulfilling both regulatory and consumer trust obligations.


9.     Potential Consequences of Inaction

  • If Monzo continues relying on unencrypted email ID checks and obscure phone quizzes, several negative outcomes could escalate:


9.1.     Regulatory Intervention

  • The ICO may investigate under GDPR, particularly if a data breach occurs.
  • The FCA or Financial Ombudsman Service could impose corrective actions or fines if users are systematically denied fair access or forced into insecure processes.


9.2.     Reputational Erosion

  • Word-of-mouth warnings might deter new customers.
  • Existing customers could switch to other digital banks that use more secure, intuitive verification channels.


9.3.     Legal Risks

  • Class actions or group complaints could emerge if multiple customers suffer identity theft due to emailing passports or if many are locked out by arbitrary phone checks.


9.4.     Undermining “Digital Bank” Credibility

  • Monzo’s brand relies heavily on innovation. Repeated stories of archaic or risky verification undermine that brand proposition.


10.      Conclusion: Criticisms, Contradictions, and the Path Forward

Despite marketing itself as a cutting-edge fintech disrupter, Monzo has been criticised for employing verification practices that some customers describe as “pirate-level”—storing or transmitting sensitive information in insecure ways and locking out genuine users based on questionable phone quizzes. These issues highlight a stark contrast between the public image of a forward-thinking, technology-driven bank and the reality of outdated or inconvenient security measures.


10.1.     Email Verification: 

  • Insecure, unencrypted, and arguably non-compliant with GDPR’s robust security demands.


10.2.     Phone Verification: 

  • Rigid, reliant on obscure pot trivia, and lacking empathy or fallback paths, causing some legitimate customers to fail security checks unfairly.


From a regulatory perspective, the bank risks running afoul of both data protection (UK GDPR) and financial conductrules (FCA Consumer Duty). From a consumer standpoint, these failures are breeding distrust and frustration, precisely the opposite of what a digital-first institution aims to foster.


Still, Monzo has the advantage of an advanced technological environment and a user base open to trying new solutions—if the bank chooses to address these lapses head-on. 


By introducing secure document-upload systems, standardising phone questions, and training staff in a more empathetic approach, Monzo could realign its operations with the modern ideals it claims to uphold. Failure to do so, however, will continue fueling the perception that Monzo is “running with other people’s money” using questionable or old-fashioned processes.


For a bank that once proudly declared it was “built to change banking forever,” the immediate priority should be to stop forcing customers to compromise their personal data through insecure channels and to start verifying them in ways that are truly consistent with the spirit of a 21st-century digital bank. Only then will Monzo shed the accusations of being a “pirate” with subpar security and fully reclaim the trust and respect it initially earned in the fintech realm.


End of  Report

Disclaimer: The above analysis is based on publicly available or commonly reported issues and commentary regarding Monzo’s verification processes. It does not constitute formal legal advice. Any regulatory implications are cited based on general references to GDPR, FCA rules, and industry best practices. For definitive guidance, consult qualified data protection or legal counsel for financial services.





This article critically examines Monzo's seemingly outdated verification methods—requesting ID selfies via unencrypted email and obscure phone quizzes about forgotten "pots." Despite presenting as a leading digital bank, these practices raise serious GDPR security concerns, frustrate legitimate customers, and potentially conflict with the FCA's Consumer Duty. The piece outlines regulatory implications, user reactions, and recommendations for Monzo to adopt modern and secure verification processes.


Below is an in-depth report highlighting criticisms of Monzo's older-style verification methods—particularly unencrypted email and obscure phone checks—despite its branding as a top-tier digital bank. This document addresses specific shortcomings, contrasts them with regulatory expectations (UK GDPR, FCA Consumer Duty), and proposes improvements.


Examining Monzo's insecure email requests and challenging phone quizzes, their impact on GDPR compliance, and recommended improvements.


1.1.     Introduction

Despite the inherent risks, sending personal data over unencrypted email remains a surprisingly common practice. In its original form, email was never designed for secure file transmission; it typically lacks robust end-to-end encryption and can be intercepted at various points. In today's data-driven world, where identity theft and cyber-attacks are rising, unprotected email exposes individuals and organizations to significant vulnerabilities. This section explores why unencrypted emails is insecure, the potential legal and financial repercussions, and how more secure alternatives better align with modern data protection standards.


1.2.     Email's Inherent Vulnerabilities

Email traffic generally passes through multiple servers without guaranteed encryption. Any malicious actor accessing a compromised network can intercept messages that are not encrypted. Stored emails might remain in plain text on mail servers, making them accessible if hackers breach those systems. In addition, phishing campaigns frequently target email accounts; once compromised, the attacker can exploit all the sensitive data in a user's inbox or sent folder. These vulnerabilities underscore that email was not designed to transmit highly confidential documents such as passports, driver's licenses, financial statements, or medical records.

1.3.     Common Types of Data at Risk

Unencrypted emails often contain government-issued identification details and sensitive financial information. Passports, driver's licenses, and confidential statements are especially valuable to cybercriminals, who can use them to open unauthorised lines of credit or carry out fraudulent transactions. When combined and sold on the dark web, personally identifiable information like full names, addresses, and birthdates can have devastating consequences. Even more troubling is the possibility of exposing medical or insurance data, which has financial implications and can infringe on a person's right to privacy.


1.4.     Consequences of Email-Based Data Exposure

When personal data is sent unencrypted, identity theft becomes significantly easier for criminals when personal data is sent unencryptedIdentity. Victims may spend years correcting their credit records, dealing with fraudulent charges, and restoring their financial integrity. Organisations responsible for the leak face legal liability, mainly if regulators conclude that insufficient security measures were in place. Beyond lawsuits and potential fines, a public data breach severely harms an institution's reputation. Customers often lose faith in entities that fail to protect their data, resulting in cancelled accounts and negative publicity. Over time, the cumulative damage can far exceed the cost of implementing secure alternatives in the first place.


1.5.     Regulatory Context and Non-Compliance Risks

In many jurisdictions, transmitting personal data via unencrypted email likely violates data 

protection rules. Under UK GDPR, for instance, organisations must demonstrate that they have taken appropriate measures to protect personal information. Article 5(1)(f) explicitly requires safeguarding data against unauthorised access or accidental loss, and Article 32 outlines the necessity for encryption and other technical measures. A single interception of sensitive data might trigger investigations by the Information Commissioner's Office, potentially resulting in hefty fines. Financial services organisations additionally face scrutiny from the Financial Conduct Authority (FCA), where insecure data handling can bring further regulatory action.
1.6.   Attack Vectors in Unencrypted Email TransmissionCriminals use various techniques to exploit plain-text email data. Man-in-the-middle (MitM) attacks enable cybercriminals to intercept or alter emails during transmission, especially on public Wi-Fi networks or compromised routers. Mailbox compromise is also a primary concern: once hackers gain access to a user's email account, they effectively acquire a treasure trove of personal information, from which they can launch more sophisticated schemes like spear phishing. Even if the immediate sender and recipient are reliable, forwarded copies and email backups create multiple weak links where data can be leaked or stolen.


1.7.     Real-World Examples of Data Exposure

Numerous high-profile cases illustrate the dangers of sending sensitive information via unencrypted channels. Organisations have been fined after their email systems were hacked, exposing thousands of customers' data. In some instances, attackers gather small fragments of PII from intercepted emails, then target individuals or customer service agents to reveal additional details. Large-scale leaks have also occurred when employees inadvertently emailed spreadsheets or documents with confidential information to unauthorised recipients. These scenarios demonstrate that unencrypted email is not merely a theoretical threat but a genuine hazard with real victims and reputational fallout.


1.8.     Best Practices for Secure Communication

Companies and individuals should opt for end-to-end encrypted services when transmitting sensitive documents. A dedicated secure portal, for instance, allows users to upload confidential files under strict encryption, with access logs and time-bound links to minimise long-term risks. If email remains the only option, password-protected attachments represent a more secure fallback. The password should be conveyed separately, for instance, by phone or text message, to avoid a single point of failure. Two-factor authentication on both the sender's and the receiver's email accounts adds another layer of protection against unauthorised access. Modern banks and fintech companies rely on in-app verification processes or websites secured via HTTPS and additional encryption, reflecting industry best practices.


1.9.     Why Some Organizations Persist with Insecure Email

Despite explicit warnings, certain institutions continue using unencrypted email because of convenience, established routines, and resistance to changing legacy systems. Staff may find it faster to email directly than implement more complex solutions, and the misconception that a small volume of transmissions poses minimal implementation risk persists. Meanwhile, fully transitioning to safer methods can require retraining personnel and investing in encryption infrastructure or secure cloud services. Unfortunately, these short-term cost savings or time benefits are overshadowed by the massive potential liabilities should a security breach occur.


1.10.     Consequences of Ignoring Security

Organisations that fail to address email-based vulnerabilities will likely face increased scrutiny from regulators as data protection laws evolve and become more strictly enforced. Data breaches can drive away customers, attract unwanted media attention, and bring legal challenges that are expensive and time-consuming to defend against. After a security lapse, regaining consumer and partner trust is often an uphill struggle, as many people prefer to move their business to providers with robust, clearly articulated safety measures. The reputational fallout can take years to mend, overshadowing any initial convenience of using unencrypted email.


1.11.     Conclusion

Sending personal data over unencrypted email is fundamentally insecure, exposing sensitive information to interception, mailbox compromise, and other cyberattacks. Individuals become vulnerable to identity theft, and organisations risk legal action, regulatory fines, and reputational damage. In an era where data privacy is paramount, entities that handle confidential information—particularly in banking, healthcare, or legal services—must adopt secure communication methods. By implementing encrypted channels, password-protected file transfers, and authentication safeguards, individuals and businesses can uphold data protection principles, demonstrate compliance, and significantly reduce the likelihood of devastating breaches.

Examining Monzo's insecure email requests and challenging phone quizzes, their impact on GDPR compli


The UK GDPR is the core data protection law in the UK, setting out principles for how personal data must be handled. Key provisions relevant to Monzo’s verification practices include:


1.    UK GDPR (UK GENERAL DATA PROTECTION REGULATION)


1.1.    Data Security (Integrity and Confidentiality – Article 5(1)(f)):

  • Organisations must process personal data “in a manner that ensures appropriate security … including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures”. This is known as the security principle, requiring firms like Monzo to safeguard customer data (e.g. account details, verification codes) from unauthorised access. Sending sensitive verification links or codes via unencrypted email could conflict with this principle if it exposes data to interception. Monzo needs to ensure that any personal data in verification processes is adequately protected (e.g. using encryption or secure channels) to comply with Article 5(1)(f).


1.2.    Lawful and Fair Processing: 

  • All personal data processing must have a lawful basis and be fair and transparent (Article 5(1)(a)). In practice, Monzo’s verification checks (email or phone) should only use customer data in ways the customer expects and agrees to – likely under the lawful basis of fulfilling a contract (providing banking services) or legitimate interests (security purposes). Monzo should also be transparent about these verification procedures in its privacy notices.


1.3.     Encryption and Security Measures (Article 32): 

  • The GDPR explicitly highlights encryption as an example of an appropriate technical measure to protect personal data. Regulators expect companies to encrypt personal data at rest and in transit, especially for sensitive information. The Information Commissioner’s Office (ICO) “requires that organisations use encryption” to protect personal data from unauthorised access. If Monzo’s current email verification links are sent in plain text (not encrypted), this may fall short of GDPR’s expected security standards. Monzo should consider stronger encryption or two-factor authentication for verification to meet the duty of Article 32 to implement appropriate security.


1.4.     Subject Access Requests (SARs):  

  • Under Article 15 of the UK GDPR, individuals have the right to access the data held by a company. A Subject Access Request (SAR) is a request made by an individual for their information. Monzo must be prepared to respond to SARs within the legal timeframe (usually one month), providing customers with details of the personal data and information on processing. In the context of verification, a concerned customer could file a SAR to find out what data Monzo holds on them (e.g. communication logs, verification call records). Monzo’s obligations under UK GDPR and the Data Protection Act 2018 mean it must securely retain these records and furnish them to the customer upon request. This incentivises Monzo to secure those records (emails, call notes).


2.    Data Protection Act 2018 (DPA 2018)

  • The DPA 2018 is the UK’s national data protection law that implements and supplements the GDPR framework. It sits alongside the UK GDPR, which governs how organisations must protect personal data. The DPA 2018 adopts the same key principles, rights, and obligations as the GDPR but also includes additional provisions specific to the UK (for example, rules for law enforcement data processing, national security exemptions, and definitions of certain offences). 


  • For Monzo, this means that beyond EU GDPR requirements, it must comply with any extra safeguards set out in DPA 2018. Notably, the DPA 2018 reiterates the duty to secure personal data and provides the ICO with enforcement powers to penalise non-compliance. For instance, the Act makes it a criminal offence for someone to obtain personal data without consent (unlawful data access) and can increase penalties if such violations occur. In essence, DPA 2018 reinforces that Monzo must implement strong data security measures (e.g. preventing unauthorised access to accounts via verification processes) or risk regulatory action under UK law. 
  • It serves as a backbone to the UK GDPR, ensuring that Monzo’s handling of customer data – including sending verification emails or conducting phone security checks – is done lawfully, fairly, and securely at all times.


3.    Privacy and Electronic Communications Regulations (PECR)

  • PECR is another piece of UK legislation that focuses on privacy in the context of electronic communications. It sits alongside the DPA 2018 and UK GDPR, providing specific privacy rights and electronic communications rules. Key aspects of PECR relevant to data security and Monzo’s practices include:


3.1.     Electronic Communications Security: 

  • PECR includes rules on “keeping communications services secure”. This is derived from the e-Privacy Directive and places obligations primarily on providers of public electronic communications (like telecom companies) to maintain confidentiality and security of communications. For example, telecom service providers must take appropriate technical measures to safeguard networks and notify the ICO and affected users if a personal data breach occurs on their service. While Monzo itself is a bank (not an ISP), this principle underscores the expectation that any company handling personal data via electronic channels should protect it. 


  • Suppose Monzo sends verification codes or login links via email or SMS. In that case, it should ensure those channels are as secure as possible (e.g. using encrypted connections or one-time links) to uphold customer privacy. Even though a standard email might not fall directly under PECR’s breach notification rule (since Monzo isn’t a telecom provider), the spirit of PECR is that sensitive personal information in electronic communications should remain confidential. 


  • Monzo’s choice to send unencrypted verification emails could be seen as contrary to the emphasis on communications security, especially if those emails contain links that grant account access. In short, PECR complements data protection law by highlighting electronic privacy – reminding firms like Monzo to be cautious with how they transmit personal data (including verification info) over the internet or phone.


3.2.     Applicability to Monzo: 

  • Monzo must also comply with PECR when it comes to certain activities – for instance if it sends marketing emails or texts, it needs customer consent as required by PECR’s direct marketing rules. Although a verification email is a service message, not marketing, Monzo should still consider PECR’s security requirements. Ensuring that customer communications (even service ones) are secure and reach the intended person helps avoid breaches of confidentiality. 


  • Additionally, if a security incident did occur (say, an email containing personal data was intercepted or misdirected), Monzo would likely inform the ICO under GDPR’s breach rules; for telecoms, PECR explicitly mandates breach notifications. The overlap of these regulations means Monzo has multiple reasons to keep electronic verification communications safe: to comply with GDPR/DPA security principles and to honour the privacy intent of PECR in electronic communications.


4.    Financial Conduct Authority (FCA) Guidelines and Rules


  • As a UK bank, Monzo is regulated by the Financial Conduct Authority. The FCA sets standards for treating customers fairly, safeguarding consumers, and handling complaints, all of which tie into how Monzo should manage verification and security procedures. Relevant FCA guidelines include:


4.1.    Consumer Duty: 

  • In 2023, the FCA introduced a new Consumer Duty, raising the bar for consumer protection. It establishes an overarching principle that “a firm must act to deliver good outcomes for retail customers”, replacing and enhancing earlier TCF (Treating Customers Fairly) requirements. Under Consumer Duty, firms must avoid causing foreseeable harm to customers, enable them to pursue their financial objectives and act in good faith. For Monzo, this means its verification practices should be designed with customers’ best interests in mind.


  • Avoiding foreseeable harm includes ensuring that security checks (like email or phone verification) do not expose customers to fraud or data theft. If sending an unencrypted email link could be exploited by fraudsters (foreseeable harm), Consumer Duty would urge Monzo to mitigate that risk – for example, by using safer authentication methods or educating customers on security. Acting in good faith and delivering good outcomes also implies being transparent and helpful: Monzo’s communications around verification should be clear (not confusing customers) and should protect them from undue risk. Failing to secure a verification process might breach the Consumer Duty, as it could lead to poor outcomes (like account takeover or distress to the customer).


4.2.     Treating Customers Fairly (TCF):

  • TCF has long been an FCA principle (Principle 6) requiring firms to pay due regard to customers’ interests and treat them fairly. It goes hand in hand with Principle 7, which mandates clear and not misleading communications. Even with the new Consumer Duty, these ideas remain essential. For Monzo, treating customers fairly means, for example, not subjecting them to unnecessary security risks or inconveniences. If a customer raises a concern that the verification process is insecure or hard to use, Monzo should address it earnestly. 


  • Fair treatment in this context could include providing a secure alternative for verification if a customer cannot access email safely or not blaming customers for fraud that occurs due to system weaknesses. Likewise, clear communication (Principle 7) means Monzo’s verification emails or phone instructions must be easy to understand and not deceptive. Any security warnings or advice should be plainly stated. By aligning with TCF, Monzo builds trust – customers feel the bank values their safety and fairness in all interactions, including account security checks.


4.3.     DISP – Dispute Resolution and Complaint Handling: 

  • The FCA’s DISP rules set out how financial firms must handle customer complaints. Suppose customers complain about Monzo’s security practices (for instance, a user might complain that sending login links via email is not secure or that phone verification questions are too easily bypassed). In that case, Monzo is obligated to investigate and respond fairly.


  • FCA rules require timely resolution – generally, a final response to a complaint should be sent within 8 weeks of receiving it (and much sooner for specific payment-related complaints). Monzo’s response should address the customer’s concerns and explain any remedial actions. For example, if a customer experienced fraud, possibly due to the email verification, under DISP, Monzo should assess if its process failed and consider compensation or changes. 


  • Monzo must also inform customers of their right to escalate unresolved issues to the Financial Ombudsman Service. In short, the FCA expects Monzo to take security complaints seriously, fix any weaknesses, and treat affected customers fairly. Consistent failures in securing data that lead to many complaints could also draw regulatory scrutiny under the FCA’s oversight.


5.      Handling of Sensitive Customer Data (FCA Expectations): 


  • Although the ICO is the primary regulator for data protection, the FCA also expects banks to protect customer data as part of their operational integrity and crime prevention duties. The FCA’s guidance on financial crime prevention explicitly notes that firms must take special care of customer’s data to prevent fraud and comply with data protection principles. Customers trust banks with highly sensitive information; if that data “falls into criminal hands, fraudsters can attempt transactions in the customer’s name,” the FCA warns. 


  • Thus, Monzo’s verification steps are not just an IT matter but a regulatory concern: inadequate data security controls could be seen as a failure of the bank’s duty to protect its customers from financial crime. FCA Principle 3 (Management and Control) requires firms to have robust systems and risk management, including IT security systems for customer authentication. The FCA might view a lapse like sending unencrypted data that leads to unauthorised account access as a breach of that principle since the firm did not adequately manage the risk. In extreme cases, the FCA can take action (fines, requirements) against a bank if poor data security results in customer harm or financial crime. 


  • Therefore, Monzo should align its practices with ICO guidance and FCA expectations, implementing strong encryption, authentication protocols, and staff training to handle customer data safely. This dual regulatory pressure (ICO and FCA) means data security isn’t just good practice – it’s essential for compliance in the financial sector.


5.    Computer Misuse Act 1990


  • The Computer Misuse Act 1990 (CMA) is the UK’s key cybercrime law that criminalises unauthorised access to computer systems and data. Its purpose is to protect the integrity and security of computer material by making hacking and other unauthorised access offences punishable by law. Under the CMA, acts such as accessing someone’s account or data without permission or even attempting to do so are illegal. 


  • This law is directly relevant to the risks posed by insecure verification processes. If Monzo’s verification email is not encrypted or easily intercepted, a malicious actor could use it to gain unauthorised access to a customer’s account – an act that would constitute an offence under the CMA. 


  • While the CMA primarily targets the perpetrator of the unauthorised access (the hacker), it indirectly creates an expectation that organisations like banks will put up robust defences to prevent such crimes. In other words, Monzo is responsible for not being the “weak link” that allows a CMA offence to occur. If a breach happened because Monzo’s security was lax (e.g. a fraudster phoned up and tricked their way through a flimsy identity check or intercepted an unprotected email link), it not only harms the customer but also means a computer misuse crime has been facilitated. 


  • Monzo should, therefore, employ strong security measures – like encrypted verification links, secure customer authentication, and monitoring for suspicious access – to help prevent unauthorised access. Doing so aligns with the intent of the Computer Misuse Act: keeping computer systems (in this case, online banking accounts and customer data) safe from intruders. Additionally, robust compliance with GDPR/DPA security requirements, as discussed above, will inherently support Monzo’s defence against CMA-type incidents. By preventing unauthorised data access, Monzo protects itself and its customers from crimes defined by the CMA.



MONZO’S OUTDATED VERIFICATION METHODS: A CRITICAL ANALYSIS

The Irony of a “Digital Bank” Using Outdated Methods

It seems deeply paradoxical for a fintech giant, celebrated for disrupting the banking industry, to rely on something as insecure as unencrypted email for identity verification. Despite lofty claims of innovation and safety, some customers are being asked by Monzo to send highly sensitive personal information—like selfies with IDs—through plain-text email. Even more confounding is the bank’s reaction when users point out the potential risks: rather than acknowledging a legitimate concern, Monzo has sometimes dismissed or belittled these warnings, making customers feel “bizarre” for wanting essential data protection. This article explores the troubling gap between Monzo’s modern image and insistence on an old-fashioned, insecure process.


Monzo revolutionized British banking by introducing instant spending notifications, easy sub-accounts (“pots”), and real-time budgeting insights. It positions itself as a leader in fintech, touting “safe and smart” technology as a core feature. However, the practice of requesting unencrypted email for confidential documents contradicts this persona in striking ways:


Tech-Savvy Image vs. Unsecured Emails

A tech-savvy financial institution would use secure portals, in-app uploads, or password-protected attachments for sensitive data. Relying on plain-text emails—an inherently insecure channel—directly conflicts with the advanced, user-centric philosophy Monzo claims to champion.


Emphasis on Security Yet Disregarding Encryption

Monzo openly states it has sophisticated fraud-detection mechanisms and prides itself on robust security measures. Encryption is a basic standard in modern cybersecurity, so refusing to offer it when collecting highly sensitive information is a glaring omission, especially for a digital-only platform.


Dismissing Legitimate Concerns

Customers who question the wisdom of sending passports and driver’s licenses via insecure email often find themselves at odds with Monzo’s support team. The resulting frustration is twofold:


Lack of Empathy

When users point out potential dangers—interception, data breaches, identity theft—they expect a responsible bank to consider safer alternatives. Instead, some customers say they were effectively told, “That’s our process. If you don’t trust it, there’s nothing more we can do.” This stance implies that the bank either does not understand or chooses to ignore basic encryption best practices.


Accusations of Being “Bizarre”

The more galling scenario is the suggestion that customers who resist sending ID documents unencrypted are the ones acting strangely. A modern, security-conscious consumer is well within their rights to question whether a bank meets legal and ethical obligations to safeguard personal data. Labelling them “bizarre” or over-cautious undermines the trust and open dialogue one would expect from a customer-centric institution.


Why Customers Are Right to Raise These Concerns

In an era where cybercrime is rampant, voicing alarm over the possibility of identity theft or a data breach is rational and necessary. There is nothing paranoid about safeguarding passports and financial details. The following points illustrate that customers have every reason to be vigilant:

  • Plain Emails Are Inherently Insecure
    • Emails typically traverse multiple servers, rarely with the robust encryption necessary to protect sensitive attachments. Any determined hacker on an insecure Wi-Fi network or a compromised email server could potentially intercept passport scans or government IDs.
  • Regulatory Mandates Favor Encryption
    • Under UK GDPR and other data protection laws, companies must show they have taken “appropriate technical measures” to secure personal data. A bank claiming to be at the forefront of technology but ignoring encrypted channels looks negligent, if not outright non-compliant.
  • Contradiction of Monzo’s Promises
    • Monzo’s entire brand is built around innovation and trust. By sticking with old-fashioned, unencrypted email processes, the bank undermines its marketing and creates a serious credibility gap with customers who believe in its digital transformation story.


The Broader Implications

The irony of Monzo’s approach may have repercussions beyond individual frustration:

  • Reputational Damage
    • Customers often share stories in forums and on social media, where other potential users learn that this “modern” bank insists on outdated, insecure practices. Over time, word-of-mouth can tarnish the bank’s image as a secure fintech leader.
  • Undermining Trust in Digital-Only Banking
    • Monzo was supposed to showcase the future of money management—quick, user-friendly, and safe. If a flagship digital bank is careless about encryption, it fuels scepticism about internet-only financial services, deterring those still hesitant to leave traditional institutions.
  • Regulatory Scrutiny
    • Should a breach occur—or if enough complaints about insecure ID submission reach the authorities—regulators may question whether Monzo has violated GDPR or other compliance requirements. The fallout could include fines and public investigations that further shake consumer confidence.


Conclusion

It is profoundly ironic that a bank acclaimed for embracing the digital future relies on unencrypted emails to transmit highly personal documents. Even more troubling is the suggestion that customers who challenge this risky approach somehow overreact. 


In reality, these users advocate for a fundamental aspect of digital security: ensuring sensitive information is protected with the same rigour the bank claims to provide. 


By dismissing or belittling these concerns, Monzo not only diminishes its credibility but risks violating the trust that propelled it into the mainstream. True innovation does not mean ignoring basic encryption; it means constantly updating and improving systems to align with ever-evolving data protection standards. 


Until Monzo implements a secure, modern method for ID verification, the gap between its marketed image and its actual practices will remain glaringly—and ironically—expansive.

Relevant UK Regulations and Guidance

6. ICO Guidance and Enforcement (Data Security & Encryption)

The Information Commissioner’s Office (ICO) oversees data protection compliance in the UK and guides procuring the secure using personal data. Key points from ICO guidance, especially relevant to encryption and Monzo’s situation, include:

Expectations of Secure Processing & Encryption: 

The ICO has repeatedly stressed that sensitive personal data should be encrypted when stored or transmitted electronically. Encryption is considered a “simple and widely used security measure” that can prevent unauthorised access to data. In practice, if Monzo emails verification links that grant access to an account or contain personal info, those emails should be protected (for instance, sent via encrypted channels or containing encrypted content) to avoid interception. ICO guidance advises that personal information transmitted over networks or held on portable devices should be encrypted and handled per the organisation’s security policies. Failing to do so could be seen as a breach of the GDPR’s security principle. Monzo should ensure it uses up-to-date encryption standards for all customer data flows – this could involve using TLS (Transport Layer Security) for emails, offering in-app or SMS verification as more secure alternatives, and never sending passwords or full security details over email. The ICO’s focus on encryption is directly applicable to Monzo’s email verification: unencrypted emails could be accessed by the wrong parties, violating the principle of confidentiality. By following ICO best practices (encryption, data minimisation in communications, etc.), Monzo can demonstrate it is handling customer authentication data responsibly.


ICO Enforcement Actions on Insecure Data Handling: The ICO has the power to investigate and fine organisations for failing to protect personal data. There is a precedent where the ICO took action for unencrypted communications. For example, the ICO fined a UK council £120,000 after a solicitor emailed highly sensitive information to the wrong recipient without encryption. The ICO deemed this a serious data protection breach and noted that if the data had been encrypted, it would likely have remained secure even if sent in error. This case underscores that regulators view unencrypted sensitive data as a significant risk. In Monzo’s context, while a verification email might not contain as sensitive information as a child protection case, it still could provide access to financial data or accounts. If such an email were intercepted and abused, and Monzo had not taken appropriate security measures, the ICO could investigate and potentially issue penalties for failing to protect customers’ data. The ICO’s guidance explicitly warns that it may take regulatory action in cases where personal data is lost or stolen and “encryption software has not been used to protect the data” Thus, Monzo faces not only customer ire but also regulatory consequences if its security checks are found deficient. To avoid enforcement action, Monzo should heed ICO guidance: for instance, use encryption and robust authentication, and limit what data is exposed during verification.Additionally, maintaining audit logs and breach response plans is crucial – should an incident occur, demonstrating a swift and adequate response can influence the ICO’s enforcement decisions. In summary, the ICO expects banks to get security right the first time; failing that, past enforcement shows that organisations can and will be penalised for preventable data security lapses. Monzo can use these regulatory pointers to bolster its verification process, ensuring that both email and phone-based security checks meet the high standards of UK data protection laws.

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