Brazil initiates second phase of Open Banking

August 19, 2021

Cybersecurity & Data Privacy and Financial Innovation

On August 13th, 2021 the Central Bank of Brazil (BCB) began the 2nd Phase of the implementation of Open Banking in Brazil which enables, on this occasion, the sharing of registration and transactional personal data in the Brazilian financial and payment market.

The Open Banking started this year on February 1st and is structured as a national model for the standardized sharing of data and services of clients from the financial and payment institutions.

Among the principles that guide the Open Banking activities, the BCB emphasizes, amongst others, that this system aims at facilitating access and control of clients over their own information that is found stored with institutions of the financial system. The 2nd Phase of the Open Banking takes a new step towards this path as it grants clients the power to transfer their data in a structured, standardized and easier way between the institutions involved in the system.

In the current Phase, in which the implementation process was divided into 4 different cicles and must be completed until October 24, 2021, the information subject to the data transfer between participant institutions and their partners includes (i) registration data of customers and their representatives (involving their identifiers, for instance), as well as (ii) transactional data resulting from specific transactions in their accounts (such as in deposit accounts, payment accounts or other credit transactions), those of which shall be taken as personal data, whenever related to individual customer information.

As a result, in addition to the specific regulation applicable to Open Banking, general personal data protection rules are also relevant in this current phase of implementation. Thus, it will be up to the participating institutions to promote an efficient and secure flow of data in attention, also, to the rights and warranties ensured to customers as personal data subjects.

Our Cybersecurity & Data Privacy and Financial Innovation teams continue to monitor the gradual implementation of Open Banking in Brazil, and we reinforce our commitment to keep you updated with any further news.

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