Data protection: Art. 29 Working Party guidelines on transparency EBF comments
EBF advisor: Hélène BENOIST k
Article 29 Data Protection Working Party:
EBF’s comments on guidelines on transparency k
Publication date: 23 January 2018 k
A technology-neutral and future-proof approach should be preferred. As tools, techniques and mechanisms constituting appropriate measures to provide information to data subjects are constantly evolving, it is imperative that the Guidelines are adjusted so that they take a technology-neutral and future-proof approach in order to allow controllers to assess the most efficient way to inform data subjects of their rights.
To decrease information overflow, emphasis should be placed on the controller’s expertise to decide the most appropriate way to allow data subjects to exercise their rights. A multi-layered approach with referrals to extra information on “clickable” texts or referrals to the general privacy statement of the given institution should be recognized as best practice. This will not only provide controllers with the opportunity to determine the most appropriate way for data subjects to exercise their rights, but help data subjects understand more thoroughly and fully exercise their rights.
Avoid confusion and misunderstanding by placing data subjects at the centre. As stated in Article 12 of the GDPR, the information provided to the data subjects needs to be concise, clear and intelligible. It is therefore essential to listen to the needs of consumers in a specific sector and to find the best way to empower citizens without overloading or burdening them with too much information.
Article 29 Working Party Guidelines need to be aligned with the GDPR and recommendations should only be provided when a “new requirement” is clearly in line with the GDPR and in the clear interest of data subjects. Both smaller, medium and large international controller groups with sophisticated and diverse processing activities need to be able to adhere to these recommendations. In their present format the recommendations only cater to controllers of basic activities.
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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