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...
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...
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.,...
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 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...
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...
