Topics covered by Cross-Border Publisher: Banking Confidentiality

Cross-Border Publisher: Banking Confidentiality from Clfford Chance Applied Solutions ("CCAS") consists of 9 questions sent by CCAS to members of the international network of Clifford Chance qualified in 17 jurisdictions. We report the jurisdictions and the questions covered in this user guide.


The jurisdictions covered are as follows: 

  • Austria,
  • Belgium,
  • Czech Republic, 
  • France,
  • Germany,
  • Hungary,
  • Ireland,
  • Italy,
  • Luxembourg,
  • Netherlands,
  • Poland,
  • Portugal,
  • Romania,
  • Slovakia,
  • Spain,
  • Sweden, and
  • the United Kingdom.


The questions in Cross-Border Publisher: Banking Confidentiality are as follows:

Local regulations or guidelines

  1. What are the laws, regulations or guidelines on banking confidentiality with respect to client data in addition to the usual (contractual or implied) confidentiality requirements?
  2. What are the banking confidentiality limitations?
  3. Do the banking confidentiality limitations apply to the sharing of client information on a need-to-know basis within a bank's group? For example, including client data in global or centralised systems such as a centrally managed data lake?
  4. Do the banking confidentiality laws still apply if the sharing of client data within the bank's group is required by law?

Pseudonymisation and anonymisation

  1. Do the banking confidentiality laws permit the sharing of client data with a third party?

Customer consent/waiver

  1. Can banking confidentiality limitations be overcome by obtaining customer consent or a waiver?
  2. If banking confidentiality limitations can be overcome by obtaining customer consent or a waiver, how can this be done?

Other technical and/or organisational requirements

  1. Are there any other technical and/or organisational requirements that a bank should undertake to allow the sharing of client data? For example, inclusion in global/centralised systems, or sharing with internal or external subcontractors?

Last updated

  1. When was this topic last updated by the Clifford Chance network of contributors?

Further Resources

To go to the product page for Cross-Border Publisher: Banking Confidentiality, click on a jurisdiction below:


Legal Information

Finally, a note on how you can use this user's guide. This user's guide is not to be considered legal advice and is not a substitute for advice from qualified legal counsel. The information we provide is not tailored to your individual circumstances, and you may not rely on it. Material aspects of the discussions in this user's guide may change at any time and without further notice. PartnerVine undertakes no responsibility to update the information in this user's guide.

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