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NEVER assume that information learned because of your job is shielded from insider trading, even for a completely different company. From ten years ago, here are two data analysts from Capital One who thought they could use the data from credit card transactions to jump the gun on quarterly earnings reports for retail stores. Never traded Capital One stock. Didn't matter - SEC hammered them.

https://www.sec.gov/litigation/litreleases/lr-23216

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I usually side with the SEC, but this is so devoid of information in a way.

Should the SEC come after someone then, if they stood outside major retail outlets across a city, surveyed buyers, and made profitable buying schemes that way?

How about analyzing satellite images of warehouse shipments? (which is a thing that is being done today)

Not everyone has access to either of those things, yet as far as I am aware, the SEC does not consider that illegal.

Why would aggregating credit card transactions be any different, honestly? Capital One already uses that information to direct its own business, much the same way.

I wish this SEC would have made it clear why this was a problem.

The only leg the SEC had to stand on in this complaint is a very specific clause from the employee agreement that says not to use this information for trading.

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