Response to discussion Paper on innovative uses of consumer data by financial institutions

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1. In what capacity (i.e. consumer, financial institution, technology providers, etc.) have you had experience with innovative uses of consumer data?

As consumer and lawyer giving advice

2. Based on your knowledge, what types of consumer data do financial institutions use most?

Offering third parties products (from TVs to bicycles)

3. Based on your knowledge, what sources of consumer data do financial institutions rely on most?

Payments data

4. Based on your knowledge, for what purposes do financial institutions use consumer data most?

Offering products and services

5. How do you picture the evolution of the use of consumer data by financial institutions in the upcoming years? How do you think this will affect the market?

They will become the future supermarkets

6. Do you consider the potential benefits described in this chapter to be complete and accurate? If not, what other benefits do you consider should be included?

Yes

7. Are you aware of any barriers that prevent financial institutions from using consumer data in a beneficial way? If so, what are these barriers?

Data protection legislation, publicity laws, and those legislation where (included the Spanish) the financial institution may be responsible of the third party products offered by their channels

8. Do you consider the potential risks described in this chapter to be complete and accurate? If not, what other risks do you consider should be included?

No. It is not included the responsibility derived from the commercialization of a third party product which includes a defect -latent or not- and, the reputation risk associated with the image of a third party vendor's image

9. Have you observed any of these risks materialising? If so, please provide examples.

No at this stage.

Name of organisation

AS LAW INTERNATIONAL BUSINESS SLP

Please select which category best describes you and/or your organisation.

[Other"]"

If you selected ‘Other’, please provide details

Lawyers