Feb 28, 2023 | Managing Data
In this statement, we outline our views on several CJEU cases that can shape the regulatory framework for the provision of credit referencing services in the internal EU market. In our opinion, cross-border access to credit databases will only be meaningful if the...
Jul 5, 2022 | Digital Transformation
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...
Jun 27, 2022 | Managing Data
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...
Mar 11, 2022 | Managing Data
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...
Feb 16, 2022 | Enabling Transactions
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...