GDPR Identity Verification

Loose Identity Verification Puts You at Risk for Fraud

Subject Access Requests (SARs) under the GDPR Now is the time to tighten up your identity verification methods. Without tight verification methods, you open yourself up to GDPR regulators and you put your customers at risk of being a victim of fraud. Individuals Can Request Access to Their Personal Data Article 15 of the GDPR gives individuals a “right of access” to their personal data, under which they can request specifics about the personal data a business holds about them, or the organization’s purpose for processing the data, the categories of personal data held, who has access to the data, whether or not it will be transferred outside of…

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EDPB Releases New Guidance: When Can Companies Rely on the Need to Fulfill the Terms of a Contract as a Legal Basis to Process?

On April 12, 2019, the European Data Protection Board (“EDPB”) published draft guidelines on the legal basis for processing personal data that involves providing online services to data subjects (the “Guidelines”). Specifically, they discuss when companies can rely on Article 6(1) – that processing can take place in the context of fulfilling the terms of a contract – and what conditions must be established to do so. The Guidelines make clear that this basis is narrower than it is often interpreted to be, and that companies must take care that they meet certain requirements. Background To lawfully process data, companies must establish one of six legal bases articulated in Article…

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