Techniques of automated decision making, including profiling are, no doubt, also of interest to financial service providers. This essay describes three such applications (credit scoring, transaction monitoring for AML purposes, risk profiling for investors) and discusses their possible compliance with the requirements under the EU’s General Data Protection Regulation, as well as the proposed new Swiss rule on automated decision-making by private persons. The discussion shows that data protection rules generally leave enough room for innovation as they focus on adequate disclosures to investors as data subjects. Material limits are more likely to be set by financial markets or consumer protection regulations, which may either limit the eligible data sources or impose quality standards on the algorithms.
From the magazine SZW-RSDA 1/2020 | S. 62-72 The following page is 62