ACCIS response to targeted consultation on AI in financial services
In our response, ACCIS notes that credit reference agencies are exploring the use of AI to help lenders evaluate the creditworthiness of individuals and businesses, as well as to establish credit scores. We highlight that AI's ability to analyse vast and complex...
ACCIS response to the European Commission’s call for evidence on the GDPR
In this response, we express concerns about perceived imbalances in GDPR enforcement. We also note that the absence of clear guidance exacerbates the situation, especially in cases where the GDPR falls short in providing necessary clarity. Members of ACCIS assert that...
Joint Industry Statement on AI Definition
In this industry statement on the AI definition, a collaborative effort signed by ACCIS and various prominent industry financial services, we emphasize that traditional, statistical techniques used in credit scoring - e.g. logistic regression - warrant regulatory...
ACCIS feedback on the European Commission’s proposal on Financial Data Access (FIDA)
In our feedback paper on the European Commission’s proposal on Financial Data Access (FIDA), we state that the proposed framework represents a positive step toward responsible and innovative financial services within the European Union. However, there are crucial...
ACCIS statement on several CJEU cases
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...
ACCIS response to public targeted consultation on Open Finance
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
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
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
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
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...