Data Protection and Data Security by Design Applied to Financial Intelligence

Abstract

EU Financial Intelligence Units (‘FIUs’) have recently started using the Ma3tch technology as additional feature to the existing exchange of information via the FIU.NET decentralised computer network. The authors of the paper analyse this concrete case of data processing as a possible practical implementation of the data protection and data security by design principle. They conclude that the Ma3tch technology can be seen as a valuable example of data protection and data security by design, as it can guarantee its fundamental elements such as data anonymisation, data minimisation and data security. Therefore, it is able not only to improve the exchange of information among FIUs and allow for the data processing in line with the applicable data protection requirements, but also remarkably enhance privacy of related data subjects. At the same time, the case study clearly shows that data protection and data security by design need to be supported and complemented by appropriate organizational and technical procedures to assure that the technology solutions devised to protect privacy will in reality do so.