Position papers Archives

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...

ACCIS response to the EBA public consultation on amending RTS on SCA and CSC under PSD2

Nov 25, 2021 | Digital Transformation

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

Oct 15, 2021 | Enabling Transactions

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...

ACCIS response to the public consultation on the future EU Data Act

Sep 2, 2021 | Managing Data

In our response to the public consultation on the future EU Data Act, ACCIS describes the data sharing activity of CRAs. Regarding the most relevant elements to increase data sharing, ACCIS agrees with the basic idea that the party sharing data obtains a reasonable...

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