EPIF response to the FSB Consultation on Data Frameworks
EPIF is delighted to share with you its contributions to the FSB consultation under the G20 Roadmap on aligning data frameworks. EPIF very much supports the efforts by the FSB to further promote the alignment and interoperability of data frameworks across jurisdictions and agrees with the overall assessment that the lack of interoperability of data [...]
EPIF response to the European Commission’s consultation on Open Finance
EPIF is delighted to share its response to the European Commission targeted consultation on a open finance framework and data sharing in the financial sector. EPIF considers that primarily Open Finance has brought more payment solutions and more options available. Notwithstanding, often provisions are not phrased in a technology-agnostic manner and can be overly prescriptive, [...]
Joint industry response to the EDPB consultation on Recommendations on measures that supplement transfer tools to ensure compliance with the EU level of protection of personal data
We endorse strong protections for personal data, including when data is transferred to third countries. We believe the Recommendations are key not only to ensuring consistency of the implementation of the CJEU’s decision in Schrems II, but also to help data exporters comply with the Court’s decision. But we have substantial concerns about some potential interpretations of the Draft Recommendations. Please see our response attached.
EPIF’s response to the Commission consultation on the European Data Strategy
EPIF is delighted to share with you its position with regard to the Commission's European Data Strategy
EPIF Response to the Article 29 Working Party Guidelines on Data Protection Impact Assessment (DPIA)
EPIF is pleased to share its response to the Article 29 Working Party Guidelines on Data Protection Impact Assessment (DPIA). For EPIF, the central question is what ‘high risk’ means to the regulators and to companies. Companies need legal certainty of how the rules will be applied.
EPIF Response to the EBA Discussion paper on innovative uses of consumer data by Financial Institutions
The European Payment Institutions Federation is pleased to share its responses to the EBA discussion paper on innovative uses of consumer data by financial institutions.
EPIF Position Paper on Safe Harbour 2.0
EPIF is pleased to share its position paper on Safe Harbour 2.0. In the context of the recent ruling of the CJEU in the Max Schrems case and the discourse which has surrounded it, EPIF would like to take the opportunity to highlight the importance of the Safe Harbour Agreement for the functioning of modern digital economies and [...]