The Italian Data Protection Authority, with the interested representative associations, has enacted on September 19th, 2019 the new rules related to the credit information systems by adopting the Code of Ethics and Conduct in Processing Personal Data within credit information systems. Amongst the most important news, to which Tonucci & Partners has cooperated with the Of Counsel Prof. Avv. Alessandro del Ninno, expert in Privacy and Partner Giorgio Altieri, expert in Compliance, on behalf of ANIASA, the national Association gathering 54 national and multinational companies providing vehicles rental, car sharing and mobility services, there is the scope of the new credit risk analysis rules, now including also the long-term rental and the operational leasing, commercial sectors not covered by the previous sectorial code. With the aim to favour the correct operations in the related markets (financial, credit, utilities, automotive), the data collected shall be processed without the interested subjects’ consent, being the applicabile legal ground of the processing the so called legitimate interest of the data controllers (companies joining the new SIC system), granting at the same time the highest level of data protection, according to the standards provided by the EU General Data protection Regulation no. 679/2016. The interested data processors have committed themselves to be bound immediately by the code of practice, notwithstanding the fact that it shall be formally enter into force once that the Monitoring Body shall have been certified by the EDPB, according to the procedure provided by art. 41 of the GDPR.
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