The Threat Landscape for Data is Changing
Today the EDPB published guidelines on the interplay between PSD2 and GDPR:
where explicit consent has differences especially for Payments Service Providers.
The consultation period ends on September 16th, 2020.
Home working post COVID (with all the data challenges this implies, not only for Traders) will likely continue into 2021 for most Banks. Data transfer, privacy, protection and collection are all impacted.
Post Brexit, if the UK is not deemed to be an adequate country from a GDPR perspective, the pan European operating model for Regional Banks will have to be examined carefully.
It seems that a revised Threat Landscape has become imperative now, coupled with the ability to flex the strategic response over the coming 12 months. Threats are not restricted to cyber risk, but are also competitive and regulatory.
We plan to add more specifics here in future, particularly in relation to Open Banking.
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