IRSG position paper on Data Protection

Published 16 Nov 2012

This position paper sets out the views and concerns of the IRSG data protection working group. We recognise the need to update the existing Data Protection Directive, aiming to create a uniform data protection regime across the European Union. However, we are concerned about the Regulation proposals as currently drafted which we believe:

  • would not deliver the discernible benefits intended for data subjects whilst placing significant additional burdens on organisations;
  • could cause inconsistency and duplication among existing EU and international laws and regulations to which financial institutions are subject;
  • could affect consumer protection measures to prevent or detect fraud or financial crime; and
  • could impact on the inward business investment into the EU.
This paper focuses on four keys areas: accountability, proportionality, use of data and extra-territoriality.

You may also be interested in the following reports on Data Protection:

IRSG high level position paper on Data Protection

IRSG commentary on data processing for compliance with legal and regulatory obligations