Ongoing advice to a bank service provider on data protection, including scoring and use of payment transaction data
Dr. Thomas Helbing
The client processes customer data of several million bank customers. I have been advising the banking service provider since 2017 on various data protection matters, both with regard to bank customer data and employee data.
- Expert opinion on the borderline between data processors and joint controllership
- Expert opinion on the permissibility of scoring (determination of the probability of default of loans) under data protection law, among others against the background of sections 10, 18, 25a KWG, MaRisk, CRR-VO.
- Drafting of declarations of consent for the use of payment transaction data (account transactions)
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