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ARTICLE · 07 DECEMBER 2017

Boiling The Ocean – Part 2

Central to every bank's compliance efforts will be the updating of contracts with existing customers and suppliers – a vast ‘repapering' exercise.

European UnionPrivacy

Read Part 1 on Why and how banks are running out of time to implement GDPR.

Repapering

Central to every bank's compliance efforts will be the updating of contracts with existing customers and suppliers – a vast 'repapering' exercise. Like the existing EU directive, the GDPR targets all firms that act as 'data controllers' – those who decide how and why data is processed, a category that covers most financial services firms – and 'data processors', typically third-party service providers that handle personal data on behalf of data controllers.

However, GDPR introduces new requirements for data controllers to explicitly obtain customers' consent on how their personal data is retained and used. Along with concerns about the additional requirements on IT systems to track these consents, some firms fear they will need completely new contracts in many cases to cover these permissions.

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