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Do I have to authorize the processing of my personal data in credit reporting systems?
When is my data entered in EURISC?
Is it true that CRIF decides whether to grant or refuse credit?
How can I check personal data about me in EURISC?
Do I have to pay CRIF a fee to obtain access to my data in the credit reporting system?
Why can't I access my data over the telephone?
Can I authorize a third party to access my data on my behalf?
How long will it take for me to get an answer to my request for access?
Can I have data about me in EURISC erased?
Can I revoke authorization that I previously granted?
How can I find out whether I authorized the processing of my personal data?
How can I correct/supplement personal data about me in EURISC?
What procedure must I follow to correct or supplement my data in EURISC?
How can I speed up the process of correcting my personal data?
How is my privacy protected?
Who are CRIF's data managers?
Do I have to authorize the processing of my personal data in credit reporting systems?
With the Privacy Authority's adoption on 16/11/2004 of the Provision on the balancing of interests (supplementing the code of conduct) has made it possible to outline cases in which the data's subject's authorization is not necessary for information to be processed in credit reporting systems.
In this case, the Authority has identified negative credit information (i.e., information regarding loans that have seen irregularities in repayment) as a category of data for which the data subject's authorization is not required. Therefore, it is not possible for this information to be revoked in any way.
Loans for which only positive data is present (e.g., credit relationships that show regular payment) require authorization in order to be processed in the system, and thus revocation is possible.
The data subject's authorization is not required for processing data about credit granted to companies, sole proprietorships, and freelance professionals.
When is my data entered in EURISC?
Your data can be sent to EURISC at three different points:
- If the participating institution wants to consult your data for preliminary examination of your credit application (if you authorized the processing of your personal data)
- When your credit application is accepted, if you authorized the processing of your personal data (PLEASE NOTE: the data subject's authorization is required only for private individuals, whereas it is not required for processing data related to the business activities of companies, sole proprietorships, and freelance professionals). Information is updated on a monthly basis with data regarding the progress of payments
- If you do not authorize the processing of your personal data, but there are irregularities in loan payments ("negative" information).
Is it true that CRIF decides whether to grant or refuse credit?
No, it is not: CRIF provides credit information to subscriber institutions from whom you have requested a loan, but does not express opinions, nor does it approve or reject your loan applications. It is the subscriber institutions themselves, based on the information that has been collected by CRIF and other data suppliers, who decide whether to accept your request, and these decisions are always made on the basis of credit policies, which may differ from one institution to another.
Moreover, under art. 5, paragraph 6 of the Code of Conduct and Professional Practice for credit reporting systems, when a credit application is not accepted, the subscriber institution informs the interested party whether in processing the request it has consulted personal data in one or more systems regarding negative credit information, and gives identifying information on the system in which such data was found and the company managing it.
How can I check personal data about me in EURISC?
You can send a written request via fax to +39 051/6458940, following the instructions listed here.
Please note: It is not possible to access your data by telephone!
Do I have to pay CRIF a fee to obtain access to my data in the credit reporting system?
Access to the credit bureau data is free of charge unless it is found to contain no personal information regarding the applicant. In this case, CRIF applies Privacy Authority Provision no. 14 of 23 December 2004 and requests a €10 contribution to expenses. This can be paid using the payment slip included with written correspondence from CRIF.
Why can't I access my data over the telephone?
CRIF Call Center operators are not authorized to provide you with your personal data over the phone, and this is precisely in order to safeguard your privacy; CRIF must be able to verify that the person making the request to access data is actually the data subject, and not someone else who might attempt to request another person's data for his own purposes (fraud, scams, etc.).
Can I authorize a third party to access my data on my behalf?
It is possible to authorize a third party to exercise your right to data access. However, we should remind you of what is established by the Code of Conduct and Professional Practice for credit reporting systems in art. 8, paragraph 3: "Any third party that is empowered by the data subject in writing to act as an attorney or delegated entity in order to exercise the relevant rights may only process personal data acquired from a credit information system for the purpose of protecting the data subject's rights, any other purpose sought by said third party and/or entities related to the latter being ruled out."
This paragraph indicates that if you access your personal data through a third party, the latter may not legally use credit information for his/her own profit or to sell services, including those of other parties.
You should note that to exercise the rights guaranteed under Legislative Decree 196/2003 (the Personal Data Protection Code), you can contact CRIF as the manager of the credit information system, or the subscriber institutions who belong to the system.
How long will it take for me to get an answer to my request for access?
The time it takes to process a request varies, and depends on its complexity and whether the application arrives in complete, legible form. We therefore recommend that you carefully follow the instructions for submitting your application (Accessing data), and that you send it only by fax, both to avoid postal delays, and so that your application file can be generated without additional processing time.
In any case, you should note that by law, CRIF has 15 days to process your request from the time of its receipt: CRIF processes requests in the order in which they are received, and therefore, although we make every possible effort to cut down on response time, we ask that you not contact the Call Center merely to insist that your request be fulfilled.
Can I have data about me in EURISC erased?
By law, you can have your personal data erased only when it has been processed in violation of the law, for example, if the data subject (the person to whom the data refers) has not authorized the processing of personal data at the time of its registration, as in the case of fraud. There are, however, set time limits for the retention of data, and upon expiration, information is automatically eliminated by EURISC, without the data subject needing to specifically request it.
You should be wary of anyone who promises you "guaranteed" erasure from the credit reporting system of any data that does not meet this condition.
Can I revoke authorization that I previously granted?
Under the Privacy Authority Provision of 16/11/2004, authorization is not required for processing data related to the business activities of companies, sole proprietorships, and freelance professionals, nor for processing negative data, even if it refers to a private individual (late payment). As a result, it is only possible to revoke authorization for processing positive data related to loans granted to private individuals, i.e., data indicating that you are someone who pays on time, with the result that only any negative data will remain visible.
For example: there are two loan entries present for your name, one in good standing and one with late payments that have not yet been settled: by revoking your authorization, you would obtain the erasure of the entry for the loan in good standing, while the one showing late payment would remain.
You should be wary of anyone who promises you "guaranteed" erasure of negative data from the credit reporting system.
To revoke authorization to process your data, you can write to the relevant bank or financial institution for that credit relationship, or you can write to CRIF, using the form on the page Accessing data.
You should note that under art. 6, paragraph 7 of the Code of Conduct and Professional Practice for credit reporting systems, CRIF enters information about this revocation and eliminates entries from the system within 90 days of receiving the revocation notice.
How can I find out whether I authorized the processing of my personal data?
If you do not believe that you authorized the processing of your personal data, you can write to the relevant bank or financial institution for that credit relationship (which is in possession of documentation about your loan) to check on the situation.
How can I correct/supplement personal data about me in EURISC?
If you want your data to be supplemented or amended, because you do not believe it is correct or up-to-date, you can contact CRIF or the subscriber institutions that entered it; if you contact the latter, you can have your data in EURISC changed directly, whereas if you contact CRIF, as the credit bureau manager, before responding it must first contact the subscriber institutions and wait for their reply to its verification reques
What procedure must I follow to correct or supplement my data in EURISC?
By law (art. 7 para. 3 of the aforecited Legislative Decree no. 196/2003) you are entitled to have your data updated or corrected if you do not believe it is up-to-date or correct. If you decide to send your request to CRIF, you can use the form on the page Accessing data. You should note, though, that CRIF cannot give you an immediate reply, since it cannot independently modify data it has received without making verifications with the financial institution that transmitted it.
CRIF will, however, see that you receive a reply within 15 days containing the outcome of the verification request or the new deadline by which you will receive a definitive answer. This deadline may not, in any case, exceed 15 more days. Moreover, you should note that during the first 15 days of verification, CRIF adds a message to your data indicating that verification of it is currently underway. If the verification process should require 15 additional days, CRIF will prevent anyone from viewing the data under verification for this latter span of time.
How can I speed up the process of correcting my personal data?
To speed up the process, it is advisable in these cases for consumers to contact the financial institution directly, since it can rapidly transmit corrections or updates to the credit bureau.
How is my privacy protected?
CRIF has adopted strict security measures in compliance with arts. 33-36 of the Personal Data Protection Code (Legislative Decree 196/2003) and annex B of the same provision.
Your credit information will only be provided to institutions to whom you have applied for a loan, and both subscribing institutions and their associates are legally required to respect your privacy.
Your data can therefore only be accessed for the purpose of limiting and preventing insolvency risk, and is not made available for marketing purposes.
Who are CRIF's data managers?
PLEASE NOTE: We should remind you that the data managers designated by CRIF and listed below are technical managers, and are not responsible for fulfilling requests for data access, correction or erasure. CRIF, as the data controller, is responsible for directly processing such applications (you can find the information for submitting these requests on the page Accessing data.)
- Postel S.p.A., with registered office in Via G. Massaia, 31 – 00154 Rome
- DataBank S.p.A., with registered office in Via Patrioti, 21 – 29100 Piacenza
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