The Pilot 3 is Personalized Collaborative Intelligence for Enhancing EmFi Services

This is the Pilot 3 – FAME FreCo Assitance Legal Contingency:

In the era of Open Banking, payment providers have significant opportunities to gain valueadded information about their services and their customers based on the aggregation, consolidation and sharing of data across institutions and organizations. The consolidation of analytics across financial organizations enables them to gain timely and accurate insights for processes like onboarding, services personalization, and credit risk scoring.

This is the Pilot 3 – FAME FReCo Assistant Guidance:

1) Type of Data: This pilot includes red-flag typology data, including personal profiles, demographic and socioeconomic information such as age, income and occupation. It also includes financial transaction data, detailing payment activities, as well as purchase history.

2) Data Subjects/Owner of the data: The data pertains to customers, specifically natural persons.

3) Purpose: The data is used to develop a red flag transaction typology, identifying patterns that may indicate unusual or suspicisous financial activities. Additionally, it supports the provision of unsupervied investment decisions.

4) Legal Obligations: The General Data Protection Regulation (GDPR) applies, requiring a lawful basis for data processing and sharing. As the data includes financial transations details, the Payment Services Directive 2 (PSD2) is relevant (and in a future the PSR or FIDA). Likewise, Digital Operational Resilience Act (DORA) may also be relevant. Moreover, copliance with the Anti-Money Laundering Directive (AMLD) for the same reasons explained in relation to other pilots. Additionally, the protection of rade secrets under Directive (EU) 2016/943 may apply, particulalry concerning the red flag typology, whih could include propetary financial risk models and methodologies that require confindentiality.

5) This analysis has been conducted based on the work completed in D6.4, and the FAME FReCo Assistance Tool has been used for each pilot.

Disclaimer

The FAME regulatory compliance tool has been developed within the context of FAME project and provides a high-level overview of relevant rules to facilitate regulatory compliance. The information provided within this online tool is for informative purposes only, and we cannot guarantee that it will suit your needs. In any case, it does not constitute legal advice, nor does it create or imply the existence of any attorney-client relationship.”