Poland: Credit Scoring in Danger?

A draft act on adjusting the Polish legal system to the provisions of the GDPR is under way in the lower house of the Polish Parliament (Sejm). The draft act (in Polish) contains, among others, provisions amending the rules for processing personal data by banks, credit institutions, loan companies and other entities regulated by Polish banking law. Particular controversy has been caused by the government’s proposal to limit the scope of data on which the credit risk scoring may be based, to only those categories of data which are expressly indicated in the draft act. In its current version, the proposed data catalogue is limited solely to identification data, data concerning marital status and matrimonial regime, information about financial and work situation, as well as credit history. Importantly, such limitation of the data catalogue excludes the possibility of using behavioral data (e.g., Internet habits including behavior in social media) in credit…

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