The Finnish Ministry of Finance has circulated for comments a memorandum on the processing of personal data of politically exposed persons using a centralised national information system (PEP register).
The objective of the centralized information system is to improve the availability, completeness, reliability and timeliness of information necessary for customer due diligence under the Finnish AML Act. The memorandum contemplates a statutory disclosure obligation for various parties regarding PEP information and focuses particularly on the processing of personal data from the perspective of data protection.
Finance Finland has in its opinion on the memorandum concluded that the need for a reliable PEP register has clearly increased since the entry into force of the AML Act, the completeness, reliability and up-to-datedness of the data in the PEP register should be ensured – the collection and maintenance of data should be designed so that the obliged entity can rely on the data without obtaining additional information from the customer to determine his/her PEP status, in addition to PEPs, the register should contain information on their family members and partners as required by the AML Act.
Finally, information about a person being entrusted with a prominent public function cannot be sensitive, which is why the PEP register should be subject to the same level of data protection as other public or commercial data sources containing the same information. The Finnish Ministry of Finance has circulated for comments a memorandum on the processing of personal data of politically exposed persons using a centralised national information system (PEP register).
The objective of the centralized information system is to improve the availability, completeness, reliability and timeliness of information necessary for customer due diligence under the Finnish AML Act. The memorandum contemplates a statutory disclosure obligation for various parties regarding PEP information and focuses particularly on the processing of personal data from the perspective of data protection.
Finance Finland has in its opinion on the memorandum concluded that the need for a reliable PEP register has clearly increased since the entry into force of the AML Act, the completeness, reliability and up-to-datedness of the data in the PEP register should be ensured – the collection and maintenance of data should be designed so that the obliged entity can rely on the data without obtaining additional information from the customer to determine his/her PEP status, in addition to PEPs, the register should contain information on their family members and partners as required by the AML Act.
Finally, information about a person being entrusted with a prominent public function cannot be sensitive, which is why the PEP register should be subject to the same level of data protection as other public or commercial data sources containing the same information.