EBF’s comments to the joint committee discussion paper
on the use of BIG DATA by financial institutions

EBF advisor: Noémie  Papp

Publication date: 17 March 2017

Key points:

• Data are at the centre of the digital revolution and consequently the use of data analytics is creating increasingly new opportunities both for consumers, who can benefit from more innovative and tailored products and services adapted to their needs, and for companies able to develop new businesses. Data analytics contribute widely to a better internal understanding of the banks’ activities, a more effective risk management, and an improved monitoring of compliance. They can also contribute to building a stimulating customer experience.

• When defining or describing the big data phenomenon we should bear in mind that it is a cross sector phenomenon. Thus a sector specific approach should be avoided as well as regulatory instruments only applicable to the financial sector. The principle “same services/risks, same rules” should apply to all companies regardless of the sector or location. The focus needs to be on assessing the activities rather than the institutions that offer them.

• Considering that further evolutions of the phenomenon are expected to emerge in the use of Big Data, the banking sector is currently assessing the applicability of Big Data and the deployment of technological developments as well as the impact of existing and recent legislations on the innovation.

• The EBF welcomes the opportunity to comment on the ESAs consultation and strongly encourages continuous dialogue between stakeholders and the policy makers, regulators, supervisors and the competent authorities such as the Article 29 Data Protection Working Party (future European Data Protection Board) to ensure the legislative framework is adjusted to the digital reality.