Data protection: Art. 29 Working Party guidelines on consent EBF comments
EBF advisor: Hélène BENOIST k
Article 29 Data Protection Working Party:
EBF’s comments on the article 29 working party guidelines on consent (wp259) k
Publication date: 23 January 2018
Supporting the clarifications on consent provided by the WP29. The European Banking Federation (EBF) welcomes the Article 29 Data Protection Authority (hereafter ‘WP29’) Guidelines on consent which is one of the central point of the General Data Protection Regulation (GDPR).
Avoiding consent and information fatigue. The banking sector supports the main objectives of the GDPR, as to increased transparency regarding personal data processing and empowering data subjects. However, it is important to avoid overburdening data subjects with too much information on too many occasions. An appropriate level of granularity needs to be found that does not lead the data subject to be nudged and bothered constantly, as this risks causing them to disengage from data protection issues.
A need to ensure a consistent consent framework. The framework for consent needs to reflect that each industry has particular challenges and differences that impact the appropriate manner in which to implement consent under the GDPR. For instance, certain provisions in these Guidelines raise questions as to the potential consequences on the lawfulness of consents given under the Second Payment Service Directive (Directive (EU) 2015/2366 – PSD2) and the Markets in Financial Instruments (Directive 2014/65/EU – MiFID II).
Future-proofing and ensuring technology-neutrality. Tools, techniques and mechanisms constituting appropriate measures to obtain consent from the data subjects are constantly evolving. Therefore, it is important to take a technology-neutral approach in order to allow controllers to best assess the most efficient way to inform data subjects and obtain consent.
We carried out a regulatory mapping exercise of crypto-assets that led to the conclusion that EU legislation would be needed in this area. We welcome the initial work done by central banks on assessing the merits of central bank digital currencies. #WEF20
The @EU_Commission intends to propose 🇪🇺 legislation later this year on a common approach to crypto-assets, including stablecoins. We need to act quickly. Already launched a public consultation on how these rules should look, everybody can contribute. It is open until 19 March‼️
It was a pleasure to share the stage with @blackrock CEO Larry Fink today! We had a great discussion about the role of the financial sector in tackling #inequality and #climate related risks. Watch it here: https://t.co/mHW5yMkLvx
The EBF is the voice of the European banking sector, bringing together national banking associations from 45 countries. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
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