Matter / Experience

Ongoing advice to a bank service provider on data protection, including scoring and use of payment transaction data

CRR-VO
MaRisk
Scoring
Account Transactions
German Banking Act (KWG)
Payment Transaction Data

Dr. Thomas Helbing

Position
Self-Employed
(Lawyer)
HELBING Kanzlei für IT- und Datenschutzrecht

München, Germany

English, German

You current availability
Available

Client Information

Description:
Service provider for banks
Branch:
Financial (Banking & Insurance)
Information Technology
Country:
Germany

Matter Details

Practice Area:
Data Protection Law
Jurisdiction:
Germany
Matter Type:
Continuous advice
Type of service:
Advice
Value:
5 - 50 Mio. EUR
Year:
2022
Work scope:
51 - 250 hours

Description

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)
  • Advice in connection with setting up own online platforms (e.g. for support), including drafting data protection notices and terms of use 
Additional Information

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