Position papers Archives

ACCIS response to public targeted consultation on Open Finance

Jul 5, 2022 | Enabling Transactions

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

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...

ACCIS feedback on the European Commission’s proposal on the EU Data Act

May 30, 2022 | Managing Data

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

Mar 28, 2022 | Managing Data

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

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...

ACCIS response to public consultation on the Mortgage Credit Directive

Feb 28, 2022 | Enabling Transactions

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...

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