Sep 1, 2020 | Managing Data
In our response to the public consultation on the inception impact assessment on the review of the Consumer Credit Directive (CCD), ACCIS states that the review should in the least touch upon the following two elements: (i) to include the principle of full-file credit...
Feb 11, 2020 | Managing Data
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...
Jan 17, 2020 | Managing Data
In our contribution to the EDPB’s draft guidelines on Data Protection by Design and by Default, we ask the EDPB to address a number of issues in relation to the examples provided in the document. In particular, in connection to the examples under “Lawfulness” i.e. a...
Feb 5, 2018 | Managing Data
In our comment letter to the Chair of the Justice Committee in the Spanish Congress of Deputies, ACCIS expresses support for the collection of positive information by credit reference agencies in that country. In our view, the adoption of a new Data Protection Law...
Jan 23, 2018 | Managing Data
In our comment letter to the Working Party Article 29 draft guidelines on Transparency, we share our remarks about: (i) the need to take into account the appropriate modality and format of the information provision to data subjects; (ii) possible solutions to avoid...
Nov 28, 2017 | Managing Data
In our comment letter to the Working Party Article 29 draft guidelines on Automated individual decision-making and Profiling, ACCIS defends that the right of data subjects not to be subject to decision-making based solely on automated processing does not necessarily...
