ACCIS response to public targeted consultation on Open Finance
In our response to the European Commission’s targeted consultation on Open Finance, we state that Open finance should complement what exists and works well in the market today: it should add value to existing markets and systems for the sharing and reuse of financial...
ACCIS response to EDPB’s Guidelines on calculation of fines
In our response to the EDPB’s Guidelines on calculation of fines, we note that the EDPB appears to emphasise setting GDPR fines at a level that effectively deters future non-compliance whilst we would prefer similar attention to ensuring the proportionality of GDPR...
ACCIS feedback on the European Commission’s proposal on the EU Data Act
In our feedback document on the proposed EU Data Act, ACCIS broadly welcomes the EU Data Act as it creates a fairer, more innovative, and more competitive data economy in Europe. We are however unclear as to the stated harmonising objective of the Regulation. The GDPR...
ACCIS feedback on a proposal establishing a European Single Access Point
In our response, we highlight that the proposal offering a single point of access to public information about EU companies and EU investment products could potentially allow ACCIS members to retrieve and process data which is used for added value services (e.g.,...
ACCIS response to EDPB’s Guidelines 01/2022 on Data Subject Rights – Right of Access
In our response to the EDPB’s Guidelines 01/2022 on Data Subject Rights – Right of Access, we highlight several positive elements in how the EDPB guides in relation to the form of Data Subject Access Requests (DSARs), the provision of a copy or the limits to respond...
ACCIS response to public consultation on the Mortgage Credit Directive
In our response to the public consultation on the Mortgage Credit Directive, ACCIS illustrates that the requirement to base a creditworthiness assessment (CWA) on information on the consumer’s income and expenses and other financial and economic circumstances which is...
ACCIS policy recommendations on the revised Consumer Credit Directive
In our policy recommendations on the revised Consumer Credit Directive, we provide an overview of the functioning of creditworthiness assessments (CWAs) and credit scores in consumer lending decisions, an analysis of the role credit databases play, and targeted policy...
ACCIS policy recommendations on the EU Act on Artificial Intelligence
In our policy recommendations on the EU Act on Artificial Intelligence we provide an overview of the functioning of creditworthiness assessments (CWAs) and credit scores in relation to lending decisions (and other service provisions) and an analysis of the role that...
ACCIS response to the EBA public consultation on amending RTS on SCA and CSC under PSD2
In our response to the EBA public consultation on amending RTS on SCA and CSC under PSD2, ACCIS notes that a consistent number of difficulties both for account information service providers (AISPs) and for open banking final users’ come from the process of strong...
ACCIS letter to the EDPS on his opinion on consumer credits
In our letter to the European Data Protection Supervisor on his opinion on the European Commission’s proposed Directive on consumer credits, we note that it is not possible to predict today what data categories could be used tomorrow to improve consumers' access to...