Handling customer information.
WHAT MAKES IT SENSITIVE
Financial data reveals behaviour, relationships, health and circumstances.
WHAT IS TYPICALLY HELD
Identity documents and identifiers Transaction history Contact details Device and location data Credit information
WHAT PRINCIPLES APPLY
Collect only what is needed Use it only for stated purposes Retain only as long as required Protect it appropriately Allow access and correction
WHAT THE TENSION IS
Retention required for anti-money-laundering purposes against deletion rights.
WHAT THAT MEANS
Deletion requests may be lawfully refused for records subject to retention obligations.
WHAT TO DOCUMENT
Which data is retained under which obligation, and for how long.
WHAT TO ENCRYPT
Data at rest and in transit, without exception.
WHAT TO RESTRICT
Access to customer data, by role, with logging.
WHY LOGGING SPECIFICALLY
Internal access to financial records is a recognised risk.
WHAT TO NEVER DO
Use customer transaction data for purposes they were not told of.
WHAT TO PREPARE
A breach response plan, including notification obligations and timelines.
WHAT TO VERIFY
Current data protection requirements, which are actively developing here.
