On October 18, 2018, the Dutch Supervisory Ascendancy for abstracts aegis adopted guidance on the added Payment Account Directive (“PSD2”). The PSD2 intends to accessible the banking casework bazaar to a beyond calibration of avant-garde online services. To that effect, the PSD2 sets out rules for accepting admission to the banking advice of coffer customers. Among added things, it provides that in best cases account providers’ admission to this claimed abstracts is accountable to consent.
The Supervisory Ascendancy credibility out that the appropriate accord is an added aegis imposed by the PSD2. It is not a acknowledged base for the processing of claimed abstracts beneath the General Abstracts Aegis Regulation (“GDPR”). In fact, beneath the GDPR the processing should not be based on consent, but rather on an another acknowledged base – namely, the beheading of an agreement. Interestingly, while the regulator acknowledges that PSD2 accord is not a GDPR consent, it applies the aforementioned accepted to both. As a result, according to the authority, the accord charge be acquired alone from the capital acceding (for example, in the anatomy of a pop-up accord request), and barter charge be able to abjure their accord at any time, an activity that would acceptable aftereffect in the end the agreement, back a provider would be clumsy to action any new abstracts thereafter.
© 2018 Covington & Burling LLP
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