EBF advisor: Elona Morina
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Publication date: 17 January 2020
The EBF acknowledges that the Directive represents an important and well-known tool supporting harmonising consumer protection rules on payment accounts within the Union. We also note that the recent transposition deadline of the Directive means that its complete impact and capabilities have still to fully unfold and it is impossible, at this point in time, to have a full assessment of the impact of the Directive in the market.
Moreover, several consumers’ satisfaction surveys undertaken in different member states show that consumers are well aware of and very satisfied with the switching services offered by their providers. For example, in a member state a 2019 study showed that awareness and satisfaction levels for the Current Account Switching Service remained consistently high at 79% and 92% respectively.
Finally, In line with the above, we also strongly recommend refraining from introducing IBAN-portability requirements without a detailed cost-benefit analysis clearly showing that the benefits for consumers outweigh the impact of a measure that would heavily damage the EU payment system.
For more information:
Elona Morina, e.morina@ebf.eu
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The post EBF’s views on the evaluation of the Payment Accounts Directive appeared first on EBF.
]]>EBF advisor: Noémie Papp
Publication date: 15 February 2017
Article 20 of the General Data Protection Regulation introduces a new right to data portability which aims at empowering the data subject by giving him/her more control over his/her personal data and encouraging free movement of data within the European Union. Data portability is central in order to provide customers with more choice, avoid data monopolies (competition issue) and allow personal data to be available to other operators (with consumer consent). Within regulated industries, customers already experience and benefit from the possibility to switch from one service provider to another.
The European Banking Federation (EBF) welcomes the possibility given to provide comments on the Guidelines prepared by the Article 29 Data Protection working party (Article 29 WP) on the right to data portability.
In our views, further considerations should be given to the need to:
- Clarify the liabilities in the application of the data subject’s right to receive personal data and the right to transmit personal data from one data controller to another data controller;
- Ensure that the scope of the right of data portability is only limited to data actively provided by the data subject to the controller (raw data);
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Ensure that sufficient security is maintained and risks prevented in the context of the transmission of personal data to the data subject;
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Ensure the framework of the right of data portability of the General Data Protection Regulation (GDPR) is aligned with recent legislative initiatives at EU level which already regulate the right to data portability (for example the Payment Accounts Directive (PAD), the new Payment Services Directive (PSD2) etc.);
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Ensure that public consultations of stakeholders will take place prior to the adoption of the guidelines with a reasonable period of response.
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Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
Subscribe to the EBF Morning Brief
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
The post EBF’s comments to the Working Party 29 : Guidelines on the right to data portability appeared first on EBF.
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