Harmonisation for Consumer Finance Organisations in the Context of the Data Protection and Passporting Directives - A Critical Review

Thomas Allen, Contracts Manager, TSYS’ International, UK
Solomon Osagie, Chief Legal Counsel, TSYS International, UK

This article looks at the conflict between commercial and legal aspects of EU policy making. In particular in the consumer finance sector whether two fundamental planks – Data Protection and Passporting - are at odds with underpinning EU philosophy of a common market and market integration; what the practical realities are for finance sector organisations operating on a global stage; whether either policy and the enabling directives behind them have achieved their stated objectives. One hypothesis is that there is a failure to understand the commercial landscape and therefore that not only have neither directives been successful in achieving business and legal uniformity but in fact that their implementation can be argued to be misleading and counterproductive in achieving the stated aim of facilitating an EU internal market

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United Kingdom Data Protection Banking & Finance November 2011 Vol. 5, No. 17, Autumn 2011

Thomas Allen


Thomas Allen is a Contracts Manager at TSYS International. A graduate of the University of Liverpool, Thomas qualified as a solicitor and was previously at PricewaterhouseCoopers Legal before he joined TSYS International’s legal department in 2010

Solomon Osagie


Dr Solomon Osagie is the Chief Legal Counsel for TSYS’ International. He obtained an LL.B in 1988 and went on to obtain an MBA, followed by a post graduate degree in law and then a doctorate in 2005 at Cambridge and Anglia Universities. Solomon was Group General Counsel at Global Switch Facilities Management before he joined TSYS. He presents regularly at legal seminars and also contributes to academic journals. He has lectured in the areas of business processes and strategy for lawyers. Solomon has received several industry nominations including one for General Counsel of the year at the 2009 British Legal Awards, corporate counsel of the year at the 2008 awards and most recently as In house Lawyer of the year at the Lawyer Awards 2010.

TSYS International


TSYS (NYSE: TSS) is reshaping a new era in digital commerce, connecting consumers, merchants, financial institutions, businesses and governments. Through unmatched customer service and industry insight, TSYS creates a better experience for buyers and sellers globally, supporting cross-border payments in more than 85 countries. Offering services in credit, debit, prepaid, mobile, chip, healthcare, installments, money transfer and more, TSYS makes it possible for those in the global marketplace to conduct safe and secure payment transactions with trust and convenience. TSYS’ global headquarters are located in Columbus, Georgia, with other local offices spread across the Americas, EMEA and Asia-Pacific. TSYS serves approximately 400 clients in 85 countries, including relationships with more than half of the Top 20 international banks. For more information, please visit us at www.tsys.com.

United Kingdom Data Protection Banking & Finance November 2011 Vol. 5, No. 17, Autumn 2011