In our contribution to inform the preparation of the European Commission’s evaluation report of May 2020 on the application of the GDPR, we take stock of our experiences implementing the GDPR in a number of areas of interest. The credit reference industry has taken GDPR implementation very seriously. The main ongoing challenges for the industry have to do with the lack of a harmonized interpretation by national Data Protection Authorities (DPAs) of some of the provisions of GDPR.

Regarding GDPR and new technologies, clarification as to how the GDPR requirements should be applied in practice would be helpful, for example a as regards the use of personal data in a fair way.