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The ICO’s Draft Guidance Leaves Unanswered Questions on Processor Obligation to Notify Infringing Instructions

Those of us who have been grappling with how best to approach GDPR compliance in outsourcing and other commercial contracts will be all too familiar with Article 28 of the GDPR. Article 28.3 builds on the limited obligations that existed under the existing regime but also include some significant enhancements…

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Global In-House Centers in India, v2.0

Global In-House Centers (GICs) were first seen in India in the 1990s as an alternative to IT outsourcing arrangements with third-party vendors. The principal driver was labor-cost arbitrage between the United States or Europe and India. The banking, financial services and insurance industries were early adopters. In their original iteration,…

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Will Anyone Pay for 1-833-AUCTION?

Toll-free telephone numbers celebrated their 50th birthday this year (frankly, without much fanfare). These numbers allow callers to reach businesses without being charged for the call. When long distance calling was expensive, these numbers were enticing marketing tools used by businesses to encourage customer calls and provide a single number for nationwide…

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911 Concerns Fuel New FCC Proceeding

Imagine dialing 911 and hearing an automated voice tell you that what you have dialed is not a valid number; or reaching a 911 call center only to have emergency personnel dispatched to the wrong location. In response to such problems, the FCC yesterday released a Notice of Inquiry (NOI)…

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The FCA Announces The Second Cohort For Its Regulatory Sandbox

The UK’s Financial Conduct Authority (‘FCA’) has now announced the participants in the second cohort of its regulatory sandbox, with the companies involved offering a range of ideas-based payment services and artificial intelligence software. In “The FCA Announces The Second Cohort For Its Regulatory Sandbox“, an article in Payments & FinTech…

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UK Government Publishes Statement on GDPR Compliance, Post-Brexit

The UK Government has published a statement of intent containing details of its proposed Data Protection Bill. The full text of the Bill is expected in September 2017, when the UK Parliament returns from its summer break. The Bill will enshrine the EU General Data Protection Regulation (GDPR) into UK…

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Has the Era of the Consumer Class Action Waiver Passed?

Financial Institutions may need to revise consumer contracts to remove class action waivers in preparation for a March 2018 federal rule. On July 19, the U.S. Consumer Financial Protection Bureau, the federal regulator for a sweeping range of depository and non-depository consumer financial services companies (including the largest of U.S.…

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Outsourcing in the Pharmaceutical and Life Sciences Sectors – a UK perspective

Pharmaceutical and Life Sciences companies operate in a demanding environment and face diverse challenges such as pricing pressure, increased regulatory requirements and mounting costs. With this backdrop, they have, starting with non-core functions, such as IT, facilities management, finance and human resources, before moving to secondary core functions, such as…

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European Banking Authority (EBA) publishes draft recommendations for outsourcing to the cloud

The European Banking Authority (EBA) has opened a consultation on its draft recommendations for financial institutions outsourcing to cloud service providers across all cloud-related domains including infrastructure as a service, platform as a service and software as a service. The recommendations are intended “to clarify the EU-wide supervisory expectations if…

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Keeping Your Airline IT Resilient

A number of major carriers have suffered high-impact IT events in the past several months. Estimates of losses in these cases have exceeded £100m. This is on top of (no doubt significant) remedial costs, reductions in share price and reputational damage. Such high-impact events are, in theory, unlikely to occur—the…

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