Consumer Credit Directive: the EDPS supports a clear definition of data to be used for creditworthiness assessment and for personalised offersc

This opinion paper goes in the direction of the paper published in October 2020 by Finance Watch, co-autered by G. Ford, P. Fox and O. Jérusalmy: “Responsible lending and  privacy protection: A consumer perspective”

A key support to our advocacy for a safer and fairer EU Consumer Credit Market

The EDPS Opinion on the proposal of Consumer Credit Directive confirms a much clearer undertanding on the way GDPR should apply to consumer credit providers, in particular as regards creditworthiness assessment and personalised offers.

Some key messages:

” To promote fair access to credit and data protection, …the EDPS recommends clearly delineating the categories and sources of personal data that may be used for the purpose of creditworthiness assessment

A clear perimeter of data to be exclusively used for CWA
The EDPS invites the legislator …to specify the categories of data that should and should not be processed.

The EDPS also recommends explicitly prohibiting the use of any special categories of personal data under Article 9 of the GDPR.

Better control of credit databases or third parties

the EDPS considers that the requirements, role and responsibilities of credit databases or third parties providing ‘credit scores’ should be addressed.

A clear perimeter of data to be exclusively used for personalised offers.

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