Article 29 Working Party: Letters to OECD and IOSCO on Financial Matters

September 18, 2014

The Article 29 Working Party did not spend the whole of its latest session discussing the right to be forgotten/right to be de-listed. It has also agreed a series of documents which have resulted in its sending letters concerning the OECD Common Reporting Standard, the G20/OECD high level principles on financial consumer protection and the International Organisation of Securities Commission (IOSCO) memorandum of understanding on exchange of information.

The letter on the Common Reporting Standard makes some ‘preliminary remarks on a number of critical data protection issues’ relating to the reporting and due diligence rules to be followed by financial institutions to identify ‘reportable accounts’. This aims to establish a global model for automatic exchange of information between states on tax evasion.  

The letter on the G20/OECD high level principles on financial consumer protection concerns the OECD Draft Effective Approaches to support the Implementation of the Remaining G20/OECD High Level Principles on Financial Consumer Protection. It refers to an Annex which refers to some ‘technical clarifications and suggestions’ in respect of data protection issues.


The letter to IOSCO concerns the Multilateral Memorandum of Understanding Concerning Consultation and Cooperation and the Exchange of Information, which aims to provide securities regulators with an international cooperation tool for combating cross-border fraud. The Working Party is concerned that the MMoU does not contain any specific provisions as regards data protection safeguards when personal data are exchanged and asks that it be ‘enhanced’ so as to include such provisions.