Analysis of Credit Reporting in Europe · 2018-11-19 · Advantages of credit information sharing A...

ACCIS 2017 SURVEY OF MEMBERS

Analysis of Credit Reporting in Europe

March 2018

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Established in Dublin in 1990, the Association of Consumer Credit Information Suppliers (ACCIS) is an international non-profit association under Belgian law bringing together 46 member organisations active in the area of consumer credit information, including 40 full members from European countries, 5 associate members from other continents, and 1 affiliate member. ACCIS’ main role consists in representing, promoting, protecting and preserving the common interests of its members. This includes in particular the representation and advocacy of members’ interests’ vis-à-vis government agencies, the public and all other third parties and to inform its members about matters of concern to them, including information about practices of other members. ACCIS aims to create a legal and regulatory climate in which its members can continue to develop their services contributing to the better functioning of the credit market in Europe and internationally.

TheinformationcontainedwithinthesematerialsisthecopyrightinformationofACCISand/oritsmembers.

Content from this report may be reproduced provided that you clearly and conspicuously state the source of the content as follows: "source ACCIS 2017 survey”.

CIVITTA is a leading independent management consultancy in the Emerging Europe with offices in Estonia, Latvia, Lithuania, Belarus, Ukraine, Serbia, Romania, the UK, Poland, Moldova, and Russia. CIVITTA provides the full span of consulting services from problem or opportunity recognition and action planning to identification of financing solutions and decision implementation support. CIVITTA helps its clients to plan activities to reach their goals, execute relevant studies, build staff know-how, find needed financing sources, or lend our human resources to jointly implement projects. CIVITTA also offers profound research and analytics services.

This report does not reflect the opinion of any institution or member associated with CIVITTA.

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Table of Contents TABLE OF CONTENTS ................................................................................................................................... 3

PREFACE .................................................................................................................................................. 4

INTRODUCTION .......................................................................................................................................... 5

What is the purpose of this survey? .............................................................................................................. 5

Advantages of credit information sharing ..................................................................................................... 6

EXECUTIVE SUMMARY ................................................................................................................................. 7

1. MARKET OVERVIEW ........................................................................................................................... 10

Ownership of the Credit Referencing Agencies (CRAs) ..................................................................... 12

2. DATA .............................................................................................................................................. 13

Types of data ..................................................................................................................................... 13

Types of organisations that supply data to CRAs ............................................................................... 16

Breadth and depth of data ................................................................................................................ 17

Data processing ................................................................................................................................. 21

What types of organisations obtain data from CRAs and the data they access ................................ 22

Services provided by CRAs ................................................................................................................. 23

Social media data ............................................................................................................................... 24

Consumer access to their data .......................................................................................................... 25

The principle of reciprocity and exceptions to facilitate access ........................................................ 28

Process and Quality Control ............................................................................................................ 31

3. LEGAL AND REGULATORY ENVIRONMENT ................................................................................................ 34

4. CROSS-BORDER DATA FLOWS ............................................................................................................... 37

5. CONSUMER GROUPS’ SUPPORT FOR DATA SHARING ................................................................................... 39

ANNEX I. WHAT DATA IS AVAILABLE AT EACH CRA .......................................................................................... 41

ANNEX II. ORGANISATIONS THAT SUPPLY DATA TO THE CRAS ............................................................................ 43

ANNEX III. PRODUCT COVERAGE (BY CRA) .................................................................................................... 44

ANNEX IV. DEPTH OF DATA BY PRODUCT ....................................................................................................... 45

ANNEX V. COMPLIANCE WITH SPECIAL STANDARDS .......................................................................................... 64

ANNEX VI. LEGAL AND REGULATORY ENVIRONMENT ....................................................................................... 65

ANNEX VII. CROSS-BORDER DATA FLOW ....................................................................................................... 74

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Preface This report summarises the results from the latest survey of ACCIS members conducted in 2017. As with the previous reports on the surveys undertaken in 2015, 2012 and 2010, this report provides an important source of information on the development of the credit reporting within Europe for all stakeholders involved in the industry.

The survey undertaken in 2017 uses a similar approach to that adopted in previous exercises, with the objective of being able to present how the key parameters and business indicators in the credit reporting industry are evolving over time. We have also introduced a few new questions in this latest survey, to cover emerging developments that are relevant to our industry such as the use of social media data and access to data by FinTech credit providers.

A key finding of the survey points to the need for increased data sharing. In addition to ‘traditional’ credit data - that should ideally include positive and negative data - there remains a potential for greater supply and usage by CRAs of alternative data. ACCIS continues to believe that improvements in the level of data shared is important for the benefit of all consumers and lenders as well as the economy as a whole.

This survey comes at a time when ACCIS members are in the process of implementing the General Data Protection Regulation. This piece of legislation will have significant bearing on the future of credit data processing and usage in Europe. We intend to use future surveys to understand the impact of this regulation on our industry.

On behalf of the Management Board of ACCIS I would like to thank all of the members who responded to the survey. I would also like to thank CIVITTA, the management consulting company that conducted the analysis of the survey results. Finally, our special thanks go to the members of the Market and Industry Working Committee, led by Management Board member Peter van den Bosch, for their invaluable guidance and input to this important project.

Enrique Velázquez

Director General

March 2018

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Introduction ACCIS is an association consisting of 46 members active in collecting and sharing consumer credit information. Among its members, there are 40 credit reference agencies (CRAs) from Europe, 5 CRAs from other continents, and 1 affiliate member. Each member strives to provide services to help creditors make better-informed decisions on their lending business. Even though the operating conditions for ACCIS members differ among countries, CRAs share the same purpose with respect to their operation. Therefore, one can expect that they perform their services in a similar way or at least hold and share information of similar nature. The General Principles for Credit Reporting developed by the World Bank, which are designed to improve standards for credit reporting on a global basis, state that the range of information held in credit reporting systems is a key component in the development of an effective credit market.

This report presents the findings of ACCIS 2017 survey of members providing responses from 32 members across 23 European countries (see Table 1). Covering a list of key questions with regard to credit reporting, it summarises the results of the fourth survey of ACCIS members and compares them with the survey results obtained in 2010, 2012, and 2015. The survey highlights the main business indicators and characteristics of CRAs, and type and quality of the data held by ACCIS member organisations, specifically its depth and breadth and the extent to which it may be used by granters. The report also describes the competitive landscape and regulatory framework in which CRAs operate.

Finally, this report includes some new questions not covered in the previous surveys. In the era of the omnipresence of social media data, the results of the survey shed some light on the use of such data and other online data by CRAs. In addition, the report covers new types of lenders, such as FinTech credit granters.

What is the purpose of this survey? The main objectives of the survey are as follows:

• to collect detailed information on the scope of data available to each Credit Reporting Agency and to determine how this data may be used;

• to identify “best practice” and to explore what improvements could be made in the credit reporting system of European countries for it to be in line with the Credit Reporting Principles drawn up by the World Bank;

• to compare the results of the present survey and the ACCIS 2015 survey, to highlight any improvements and any issues that remain unsolved and need attention;

• to examine similarities and differences and to outline the cause, nature, and potential impact of such differences.

To achieve the objectives stated above, the analysis was undertaken in 4 stages (see figure 1 below).

Figure 1 Methodology applied

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While this survey was carried out on behalf of the members of ACCIS, its results will be of interest to other stakeholders of the credit reporting system, particularly lenders who supply and access the data held by CRAs, consumer organisations, regulators and policy makers.

Advantages of credit information sharing A well-balanced and managed credit reporting system should benefit lenders, borrowers, and the economy as a whole. It does so by reducing the potential of inappropriate lending or borrowing, thus helping to avoid economic peaks and falls and smoothing out economic cycles. The world financial crisis proved that the large-scale inappropriate lending can have a widespread adverse effect on many parties. It can lead to recession and/or years of budget austerity, which is often necessary to restore the balance.

Credit information sharing ensures better access to information at the level of borrowers and lenders and reduces information asymmetries between them. Therefore, it acts as a key element in:

• Increasing access to credit under lower interest rates for good borrowers. Effective credit referencing systems help to evaluate risks, allow to make more appropriate decisions, and limit lending to borrowers who are more likely to default (due to the size of their outstanding debt or other reasons). Thus, it enables creditors to charge lower risk premiums and reduce the cost of borrowing for good borrowers.

• Preventing over-indebtedness by ensuring that lenders have a clear picture of the amount of debt held by a borrower so that effective decisions can be made to avoid burdening borrowers with debts they cannot repay.

• Supporting responsible lending by helping lenders and borrowers make decisions based not only on their current ability to pay (affordability), but also on their history of debt repayments.

• Supporting financial inclusion by helping potential borrowers build a credit history to show how they are managing their existing or past debts.

• Supporting fairness in lending by enabling lenders to create lending policies and implement these policies on the basis of consistent and accurate information so that lending decisions could be made fairly with respect to the applicants.

• Preventing or detecting fraudulent activities by using information to identify unusual activities indicative of actual or attempted fraud.

• Improving borrower discipline by helping consumers gain a clear picture of their own "financial standing". The availability of such information may lead to more responsible financial management and may force borrowers to better manage their own financial situation.

• Providing accurate information to help lenders collect debts from borrowers who are not repaying their loans according to their contractual obligations. Lenders may also use such information to determine whether legal actions to recover debts are suitable.

• Supporting bank supervision and credit risk monitoring.

In a nutshell, in competitive markets the benefits of credit reporting activities are passed on to borrowers in the form of a lower cost of capital, which, in turn, has a positive impact spending and investment. Improved information flows also provide the basis for fact-based and quick credit assessments, thus facilitating greater access to credit and other financial products.

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Executive Summary The main findings of the 2017 ACCIS Member Survey are grouped into five categories, according to the structure of the survey and this report.

Data Data Processing & Quality

Legal & Regulatory

Environment

Cross-Border Data Flows

Consumers` Support for Data

Sharing

DATA

Most CRAs hold and collect information on mortgages, consumer loans, credit and store cards, and borrowing on a current account Consistently with the results of the 2012 and 2015 surveys, the depth of the data on “mainstream” lending products covered by CRAs, such as consumer loans, credit and store cards, mortgages, and overdrafts, is the highest in terms of both negative and positive data Credit application, portfolio monitoring, and identity checking are the most frequently used services by clients of CRAs Banks, leasing companies, credit card and retail credit suppliers as well as mortgage providers and credit unions are the most advanced users of CRAs services Only 3% of organisations use social media data for the purpose of creditworthiness assessment There remains a potential for a greater supply and usage by CRAs of 'alternative data', such as data from companies providing utilities and telecommunications services. Likewise, utility and telecommunications providers could use services provided by CRAs to a greater extent. The potential of a more extensive use of social media and online data could be further explored by the credit reporting industry.

DATA PROCESSING

& QUALITY In 72% of cases, data is shared and accessed under a reciprocal basis 72% of respondents confirmed that they have mechanisms in place to secure purpose limitation Access to data for better evaluation and monitoring of securitised debt could be improved to support the reinvigoration of securitisation market

69% of consumers have free access to their data, in all cases consumers have the right to access their data. In 100% of cases the consumer has the right to dispute, yet only in 22% of cases the consumer has a right to add comments to his/her file. CRAs in general promote consumers' access to their credit file.

63% of CRAs, comparing to 58% in previous periods, provide educational information materials to help borrowers improve their “financial standing”

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CROSS-BORDER DATA FLOWS

Lack of demand and restrictive or unclear regulatory framework are the main obstacles of cross-border data sharing. More precise and clear legislation would facilitate cross border data sharing

37% of respondents share data across borders Only 16% of European members who responded to the survey share data with financial institutions in other countries, and 16% access data from them directly

CONSUMERS` SUPPORT FOR

DATA SHARING Decreasing trend of consumers’ support to data sharing can be addressed by regular contact with these groups

The consumer support to data sharing seems to have decreased in European countries (50% of respondents reported such support in 2017 in comparison to 59 % in 2015) Data privacy and data security remain key concerns of consumer groups

LEGAL & REGULATORY

ENVIRONMENT The number of respondents who reported the existence of legislative barriers to data sharing has dropped from 69% in 2015 to 38% in 2017

Restrictive or unclear regulation as e.g. uncertainties in the reading of the upcoming GDPR is still the main obstacle for data sharing among ACCIS' European members. There is room to improve the regulation in order to make it more clear and supportive for credit reporting agencies

Data Protection regulations are the main regulations that CRAs face at both national and EU levels Sharing of credit data is required by regulation in 63% of cases and of non-credit data in 22% of cases, comparing to 41% and 17% respectively in 2015

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SURVEYRESULTS

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1. Market overview This chapter provides an overview of the credit reporting market in Europe based on responses of 32 members from 23 countries.

Table 1 List of respondents

Country code

Country Member Member short name

AT Austria CRIF GmbH CRIF AT AT Austria KSV1870 Information GmbH KSV 1870 BE Belgium Banque Nationale de Belgique BNB HR Croatia HROK d.o.o. Croatian Credit Information Registry HROK CY Cyprus Artemis Bank Information Systems Ltd Artemis CZ Czech Republic SOLUS SOLUS CZ Czech Republic CRIF – Czech Credit Bureau, a. s. CRIF CZ DK Denmark Experian Denmark Experian DK FI Finland Suomen Asiakastieto OY Suomen DE Germany Creditreform Boniversum GmbH Creditreform DE DE Germany SCHUFA Holding AG SCHUFA EL Greece Tiresias Tiresias HU Hungary BISZ Central Credit Information Plc BISZ IS Iceland CREDITINFO GROUP CREDITINFO IT Italy CRIF S.p.A. CRIF IT IT Italy Experian-Cerved Information Services S.p.A. Experian IT PL Poland Biuro Informacji Kredytowej S.A. BIK PL Poland ERIF Biuro Informacji Gospodarczej S.A. ERIF XK Republic of Kosovo Central Bank of the Republic of Kosovo CBK RO Romania S.C. Biroul de Credit S.A. Biroul de Credit RU Russia Closed Joint Stock Company "United Credit Bureau" UCB RS Serbia Association of Serbian Banks Serbian CB ES Spain Experian Bureau de Crédito S.A. Experian ES ES Spain Equifax Spain Equifax ES SK Slovakia CRIF SK CRIF SE Sweden UC AB UC AB SE Sweden Creditsafe i Sverige AB CREDITSAFE CH Switzerland CRIF AG CRIF CH NL The Netherlands BKR Stichting Bureau Krediet Registratie BKR GB United Kingdom Experian Experian UK GB United Kingdom Equifax Limited Equifax UK GB United Kingdom Callcredit Information Group Ltd Callcredit

For the full list of ACCIS members, please refer to the website of the Association: www.accis.eu

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Out of the 32 ACCIS members who took part in the survey, members from 14 countries reported that there are other CRAs in their countries, while in 9 European countries ACCIS members are the only CRAs in that country.

Countries covered by respondents Countries not covered by respondents

Figure 2 Countries covered by ACCIS members that responded to the survey

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Ownership of the Credit Referencing Agencies (CRAs)

The survey shows a wide diversity of ownership forms. In the year 2017, 34% of all respondents were subsidiaries of larger groups - the same percentage as in 2015, compared to 13% in 2015. 25% of CRAs in 2017 stated that they are commercial listed companies, 13% (21% in 2015) were owned by lenders' associations, 10% (14% in 2015) were owned by the government, and 19% account for other types of ownership. These differences could be assigned rather to a different group of respondents in 2017 than to changes in ownership preferences.

Consistently with the previous surveys of ACCIS members, the results of the 2017 survey show that the majority of the respondents (81 %) operate on a for-profit basis. CRAs that offer their services on a non-profit basis operate in the following countries: Belgium, the Czech Republic, the Netherlands, Kosovo, Serbia, and Cyprus.

More than a third (38%) of respondents are CRAs that employ between 50 and 100 people. Another 31% of respondents are represented by CRAs that employ more than 200 people.

Figure 3 Ownership structure of CRAs

Figure 4 Credit reporting business model

Figure 5 Number of employees

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2. Data Quality of information is a key element in ensuring an effective credit reporting system. Data should be accurate, complete, and up-to-date so that lenders and other users of the information could make better decisions. The World Bank General Principles for Credit Reporting state that “quality also means that data is sufficient and adequate, implying that: i) relevant detailed information is captured, including negative as well as positive data; ii) information from as many relevant sources is gathered, within the limits established by law; iii) information is sufficient in terms of the period over which observations are available".1

Types of data The survey shows that all CRAs, collect data on individuals, and that all CRAs, except for 4 members, collect data on sole traders. Most members also collect data on SMEs and larger corporate entities. Data on other legal entities such as municipalities, economic associations, non-profit organisations, and housing associations are also collected by some credit bureaus.

Note: Suomen Asiakastieto OY from Finland holds only negative data obtained mainly from public sources following a decision of a court or a similar public authority.

Most members collect data on borrowers, including name, date of birth, and taxpayer number or other unique identification number. Very few members collect family group data, which can be useful to show high inter-dependence of the finances of spouses or partners, other family members, and the debts of household. In particular, most CRAs are not permitted by law to link together family data or make it available for use in lending decisions. Only CRAs in the Switzerland, Sweden, United Kingdom, Cyprus and Austria are allowed to associate family group data about other family members (See Table 3 and Figure 8 below, and Table 10 in Annex I to this report).

1 The World Bank, "General Principles for Credit Reporting", 2011, p. 4.

Table 2 On what type of borrowers does your organisation collect data from providers?

* incl. economic associations and other foundations

AT AT BE HR CY CZ CZ DK FI DE DE EL HU IC IT IT PL PL XK RO RU RS ES ES SK SW SW CH NL UK UK UK

Organisations CRIF

KSV

1870

BNB

HRO

K

Art

emis

Ban

k

SOLU

S

CRIF

Expe

rian

DK

Suom

en

Cred

itref

orm

SCH

UFA

Tire

sias

BISZ

CRED

ITIN

FO

CRIF

S.p

.A.

Expe

rian

BIK

ERIF

CBRK

Biro

ul d

e Cr

edit

UCB

ASB

Expe

rian

Equi

fax

CRIF

Cred

itsaf

e

UC

AB

CRIF

AG

BKR

Expe

rian

Equi

fax

Callc

redi

t

Individuals ### ### ### ### ### ### ### ### ### ### ### ### ### ### ### 1 1 ### ### ### ### ### ### ### ### ### ### ### ### ### ###Sole traders ### ### ### ### ### ### ### ### ### ### ### ### ### 1 1 ### ### ### ### ### ### ### ### ### ### ### ###SMEs ### ### ### ### ### ### ### ### ### ### ### ### ### 1 1 ### ### ### ### ### ### ### ### ### ### 1Large companies ### ### ### ### ### ### ### ### ### ### ### 1 ### ### ### ### ### ### ### ### ### 1Municipalities ### ### ### ### ### ### ### ### 1Associations & Non-profits* ### ### ### ### ### ### ### ### ### ### ### ### 1Housing association ### ### ### ### ### ###All forms of legal entities ### ### ### ### ### 1 ### ### ### ###Other groups ### ###

### Not collected dataCollected data

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Figure 9 shows what data has been collected since the first survey was conducted in 2010 (in the first row the total number of CRAs that have submitted responses to each of the previous surveys and to the current survey is indicated. In the subsequent rows, the number of CRAs that reported to collect respective categories of data during each of the four surveys is indicated.

Some data collected by CRAs is used to create intelligence or supplement missing data. For example, some CRAs have access to data on income or data that can be used as a proxy for income. Some CRAs also extract intelligence from the data to create links between people and/or businesses, and people and locations.

Figure 6 Is there a threshold amount for initial data entry below which data is not collected?

Figure 7 Are you allowed to associate family group data about other family members?

Figure 8 Can lenders use data applicant and its family members to make decisions?

Table 3 Consumer identity, income and asset, bankruptcy and court data by country

AT BE HR CY CZ DK FI DE EL HU IC IT PL XK RO RU RS ES SK SW CH NL UK

Name ## ## ## ## ## ## ## ## ## ## ## ## 1 ## ## ## ## ## ## ## ## ## ##Other or previous name ## ## ## ## ## ## ## ## 1 ## ## 1 ## ## ##Taxpayer ## 1 ## 1 ## 1 1 ## ## 1 1 1 ## 1 1 ##Date of birth ## 1 ## 1 ## 1 1 1 1 ## ## 1 1 1 ## 1 1 1 ## 1 1 1Place of birth ## 1 ## 1 1 ## ## 1 1 ## 1 1 1Gender ## 1 1 1 ## 1 1 1 ## ## 1 1 1 ## 1 1 1 1 1Addresses ## 1 1 1 ## 1 1 1 1 ## ## 1 1 1 ## 1 1 1 1 1 1 1Family group data ## 1 ## 1 1 1 1 1Others 1 1 1 1 ## 1 1 1

Employer identity 1 1 1 1Income 1 1 1 1 1 1Assets 1 1 1 1 1

Bankruptcy/incolvency data 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1Court judgments 1 1 1 1 1 1 1 1 1 1 1 1 1 1

Consumer/borrower identity data

Consumer/borrower income/asset data

Consumer/borrower bankruptcy/insolvency and court data

Collected or accessible data Not collected and not accessible data

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In 25% of cases (8 CRAs), there is a financial threshold below which data is not collected. This threshold ranges from 20.06 EUR (200 SEK) in Sweden2 to 300 EUR in Austria. In 3 out of 8 cases, this amount differs by product, and in 5 cases, it is the same for all product categories. 9 CRAs also have a financial threshold below which data is not collected for arrears. The amount varies from country to country and can be as low as 6.80 EUR (30 RON) in Romania and as high as 40.5 EUR (50,000 ISK) in Iceland for non-consumer data. For detailed description of financial thresholds please refer to Table 16 in Annex I.

There is no unified definition of default used by CRAs. Even though the definition of default is consistent in 68% of cases (22 CRAs), it still differs in 31% of cases (10 CRAs).

2 The threshold below which data is not collected in Sweden has increased from 100 SEK in 2015 to 200 SEK in 2017.

Figure 9 Consumer identity, income and asset, bankruptcy and court data dynamics by CRAs

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Types of organisations that supply data to CRAs

To ensure that data is sufficient and complete, CRAs should be able to gather information from all relevant data providers. Banks, leasing companies, credit card suppliers, and credit retail suppliers remain the core sources of data for CRAs. CRAs from the UK, Germany, Denmark, Switzerland and Poland have the most data sources, while CRAs from Finland, Serbia and Cyprus have the least.

Even though utilities providers, such as energy (electricity, gas, heat) or water providers, have information that might be of use in credit reporting systems, they provide the necessary data only in some countries (mostly in the Top-5 countries that have the largest number of sources of data – see Table 4 below). The situation has not changed much since 2015.

While telecommunication providers also possess valuable alternative data that can be used to improve lending decisions, their position as a source of information has not changed significantly since 2015.. Therefore, in many countries there is a potential to use alternative data from utilities providers and telecommunication companies to a greater extent. Indeed, nowadays non-financial lending sectors collect useful information that can be extremely helpful in allowing non-banked or unserved population to become eligible for credit.3

Empirical evidence shows that “alternative data, if widely incorporated into credit reporting can bridge the information gap on financial risk for millions of people”.4 However, this can happen only if this information can be shared amongst lenders. ACCIS therefore agrees with the recommendation laid out in the General Principles of Credit Reporting, namely that regulators and legislators should ensure that powerful and predictive information does not remain unutilised because of the lack of regulations or because of excessive regulatory restrictions.5

Table 4 Top 5 and Bottom 5 countries in terms of data sources in 2017 vs. 2015

Countries that have the most sources of data: Countries that have least sources of data: 2017 2015 2017 2015 1. The United Kingdom (21) 1. The United Kingdom (19) 1. Finland (3) 1. Cyprus (3) 2. Germany (21) 2. Poland (19) 2. Serbia (3) 2. Serbia (3)

3. Denmark (20) 3. Switzerland (17)) 3. Cyprus (3) 3. Romania (4) 4. Switzerland (18) 4. Germany (16) 4. Republic of Kosovo (3) 4. Croatia (4) 5. Poland (17) 5. Denmark (15) 5. Slovakia (4) 5. Finland* (4)

Note: Numbers in brackets indicates number of organisations that supply data to the credit reporting agency in the country * In Finland data was not provided directly to the CRA

The number of organisations providing data to CRAs is normally a function of the level of development of credit reporting in the particular country.Please refer to Table 5 for a breakdown on a country level and to Annex II for a CRA level breakdown.

3 Oscar Madeddu, IFC intervention at the European Parliament, The Role of Credit Reporting Agencies In Today’s Financial System, Brussels September 17, 2015 4 PERC / Infopolicy, “Give credit where credit is due”, 2006, http://perc.net/content/give-credit-where-credit-due-increasing-accessaffordable-mainstream-credit-using-alternative 5 The World Bank, "General Principles for Credit Reporting", 2011, p. 36.

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Breadth and depth of data To enable appropriate evaluation and management of credit risks on a continuous basis, collected data should include all the relevant information: both negative and positive, as well as other appropriate information. According to the World Bank6, “credit reporting service providers should set up clear rules on minimum data inputs and optional data inputs. Data elements to be collected should include, at a minimum: identification information, information on the credit including original amount, date of origination, maturity, outstanding amount, type of loan, default information, arrears data and transfer of the credit when applicable. Ideally this would also include credit risk mitigation instruments such as guarantees, collaterals and an estimate of their value.” This section of the report analyses the breadth and depth of data held by respondents and suggests areas for improvement to assist both lenders and borrowers.

6 The World Bank, “General Principles for Credit Reporting”, 2011, p. 25

Yes, organisations supply data to CRA In discussionsNo, organisations doesn't supply data to CRA Not answered

Table 5 What types of organisations supply data to the credit reporting agencies, by country?

AT BE HR CY CZ DK FI DE EL HU IC IT PL XK RO RU RS ES SK SW CH NL UKBanks 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1Credit unions 1 1 1 1 1 1 1 1 1 1 1 ## 1 1 1Debt collectors / debt purchasers 1 1 1 1 1 1 1 ## 1 ## 1 1 1 1Leasing 1 1 1 1 1 1 1 1 1 1 1 1 1 ## 1 1 DP 1 1 1Credit card suppliers 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1Retail credit suppliers 1 1 1 1 1 1 1 1 1 1 ## ## 1 1 1 1Health insurance ## 1 1 1 ## ## ## 1Other insurers ## 1 1 1 DP 1 1 ## ## ## 1 1 1Energy 1 1 1 1 1 DP 1 ## 1 ## 1 1 1Water ## 1 1 1 1 ## 1 ## 1 1 1Telecommunication companies 1 DP 1 1 1 1 DP 1 ## 1 DP 1 1 1 1Television suppliers 1 1 1 1 DP 1 ## ## ## 1 1Internet providers 1 1 1 1 1 1 ## ## ## 1 1 1Mortgage providers ## 1 1 1 1 1 1 1 1 1 1 1 1 ## 1 1 1 1 1Home rental companies 1 1 1 1 ## ## ## 1 1 1Brokers/Intermediaries ## 1 1 1 ## ## ## 1 1Courts ## ## 1 1 1 1 1 1 ## ## ## 1 1 1Government departments ## 1 1 ## 1 1 1 1 1 ## ## ## 1 1 1Crowd-funding platforms ## 1 1 ## ## ## DP 1Payment services providers 1 1 1 1 ## ## ## 1 1 1Tax authorities ## ## 1 ## 1 1 ## ## ## 1 1 1Police ## ## ## 1 1 ## ## ## ##Central banks ## 1 ## ## ## ## ## 1Acquirers of credit portfolios ## 1 1 1 1 ## 1 ## 1 1 1 1Investors ## 1 ## ## ## ##Others ## 1 ## 1 ## ## ## 1 ## ## ## 1 ## ## 1

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Breadth of data

Breadth of data refers to the level of credit product coverage in the credit bureau and is essential in providing a complete picture of the liabilities of the party concerned. Whilst many credit reporting systems start out with banking data, several have moved beyond that to hold data from other lenders such as leasing and retail credit companies and, in some cases, payday and SMS loans suppliers, and communications suppliers such as telephony (fixed and mobile), as well as utility providers like energy and water.

Most CRAs hold information on mortgages, consumer loans, and credit and store cards (see Tables 6 and 7). Overdrafts are also covered in majority of ACCIS members’ countries. On the other hand, there are significant gaps in coverage of telecommunication, TV and Internet services, utilities and low value credits (payday loan and SMS loan) data across countries. CRAs in Switzerland, UK, Germany, Denmark, and Poland reported the highest coverage in terms of number of different credit products. For comparison, in 2015 the highest coverage was reported by the respondents from Switzerland, UK, Austria, and Poland. Cyprus, Romania, and Serbia reported the least number of products being covered. In terms of types of credit, home rental and health insurance are the least covered products.

15 CRAs from 13 countries cover both positive and negative data on point of sale credit. Only 12 out of 31 members who responded to the survey cover both types of data on mobile telecommunications, while both type of data on low value loans are covered by 17 members in 12 countries. Utilities such as gas, electricity and water, and other services such as mail order, Internet service, satellite/cable TV and broadband, exhibit low coverage by CRAs, and mostly negative data is captured for these categories. Data on home rent and health insurance has the least or no coverage. These results are largely the same as the results of the 2015 Survey regarding the product coverage. For a breakdown of this information by CRA, please refer to the Annex III, Table 13.

NAYes, both positive and negative No, only negative

Table 6 Do you collect and hold both positive and negative data, by country?

AT BE HR CY CZ DK FI DE EL HU IS IT PL XK RO RU RS ES SK SW CH NL UKMortgage 1 1 1 1 1 99 0 1 1 1 1 1 1 1 1 1 1 0 1 1 1 0 1Consumer Loans 1 1 1 1 1 1 0 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1Credit and store card 1 1 1 1 1 1 0 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1Mail order 99 1 99 99 0 1 0 1 99 0 0 5 0 0 99 99 99 0 0 1 99 1Point of sale credit 1 1 1 99 1 1 0 1 99 1 0 5 0 0 99 1 99 0 1 0 1 1 1Energy (gas, electricity, oil) 99 99 99 99 0 1 0 1 99 0 1 5 1 0 99 0 99 1 0 1 99 1Water 99 99 99 99 0 1 0 1 99 0 1 5 1 99 99 0 99 1 0 99 99 1Education loans 99 1 1 1 1 0 0 1 1 1 1 1 1 0 99 1 99 0 0 1 99 1Credit line on a current account 1 1 1 1 1 1 0 1 1 1 1 1 1 1 1 1 1 0 0 1 1 1Internet service provider 99 99 99 99 1 1 0 1 99 0 1 5 1 0 99 0 99 1 0 1 99 1Satellite/cable TV 99 99 99 99 0 1 0 0 99 0 1 5 1 0 99 0 99 0 0 1 99 1Fixed line Telecoms* 99 99 99 99 1 1 0 1 99 0 1 5 1 0 99 0 99 1 0 1 99 1Telecoms - mobile 99 99 99 99 1 1 0 1 99 0 1 1 1 0 99 0 99 1 0 1 1 1Payday loans/SMS loans 99 99 99 99 1 1 0 1 1 1 1 5 1 0 99 1 99 1 1 1 0 99 1Home rent 99 99 99 99 0 1 0 0 99 0 0 5 1 0 99 0 99 0 0 0 99 1Leasing 1 99 1 1 1 1 0 1 1 1 0 1 1 1 99 0 99 0 1 0 0 1 1Health insurance 99 99 99 99 0 1 0 0 99 0 0 5 0 0 99 0 99 1 0 0 99 0Other insurances 99 99 99 99 0 1 0 0 99 0 0 5 1 1 99 0 99 1 0 1 99 0Others 99 99 1 99 1 99 0 1 99 1 99 5 99 0 99 99 99 1 1 0 1 1 0

19

Depth of data

Depth of data refers to the amount of information held about a credit agreement and is commonly classified as follows:

• Negative: covers the worst states of arrears that might be described as default (generally 60 or 90 days or more in arrears) and the non-payment leading up to that position.

• Positive: covers facts of contractually compliant behaviour. It includes detailed statements about outstanding credit, amount of loans, repayment patterns, assets and liabilities, as well as guarantees and/or collateral. The extent to which positive information is collected typically depends on national legislation, including the data protection regime.

With certain types of credit products, other information might be relevant as well. For example, for revolving credit it is important to know if the balance is being paid off each month or not and if cash is being drawn against the instrument. In the case of short-term loans such as payday loans or SMS loans, it is helpful to know if they have been extended or rolled over.

To enable lenders to make better decisions, the data should be available not only when the account is open, but also for a period after the account is closed or settled.

“Traditional" credit products covered by CRAs, such as consumer loans, credit and store cards, mortgages, credit line on current accounts (overdrafts) and leasing, have the highest depth of data collected by CRAs on these products in terms of both negative and positive data (as mentioned above, the breadth or coverage of data on such products (product coverage) is also the highest in comparison to other products).

Almost all members collect data on defaults, amount outstanding and duration of the loan on consumer loans, credit and store cards, mortgages and credit granted on current accounts. Negative data on arrears, write-offs and positive data about original contract, payment terms and on-time payment history is covered by more than half of the CRAs that responded to the survey. Please refer to Annex IV for detailed description of depth of data by product for each of the CRAs.

Figure 10 Country level summary for data collection of both positive and negative data, by country

Yes, both positive and negative No, only negative

Zero CRAsFrom 1 to 5 CRAs

From 6 to 10 CRAs

From 11 to 15 CRAs

From 16 to 20 CRAs

More than 21 CRA

Number of CRAs that provide organisations with specific type of data:

Table 7 Product coverage and depth of the data: Do you collect and hold both positive and negative data?

Default (>3 months)

In arrears (1-3 months)

Rejected cheque list

Number of missed Write-offs

Original contract Outstanding

Payment terms

Interest rate

Duration of loan

On-time payment

Mortgage 28 4 25 19 1 15 13 22 22 17 5 20 16Consumer Loans 28 3 28 19 1 16 17 23 22 16 5 20 15Credit and store card 28 3 28 19 1 16 17 22 21 16 4 19 14Mail order 7 16 8 3 0 4 2 3 3 5 1 2 2Point of sale credit 15 11 18 11 1 11 14 14 11 13 2 13 10Energy (gas, electricity, oil) 9 15 11 4 0 5 3 3 3 2 0 1 1Water 8 15 7 3 0 2 2 2 3 1 1 1 1Education loans 16 12 15 12 1 10 10 12 12 10 2 11 10Credit line on current account 25 6 23 17 2 12 17 20 18 14 5 17 13Internet service provider 8 16 9 3 0 3 1 1 2 1 0 0 1Satellite/cable TV 6 18 7 3 0 3 1 2 2 1 1 1 1Fixed line Telecoms* 9 15 10 12 0 12 12 4 2 4 1 1 2Telecoms - mobile 12 13 12 4 0 5 4 12 4 0 5 4 15Payday loans/SMS loans 17 8 16 13 1 11 10 16 13 2 10 10 5Home rent 3 20 4 10 0 10 11 2 2 1 1 1 1Leasing 16 12 19 13 0 10 13 15 14 12 3 13 10Health insurance 2 22 3 0 0 0 0 1 1 0 0 0 0Other insurances 6 17 8 3 1 2 6 3 3 2 2 2 1Others 7 10 15 9 0 10 10 6 6 4 0 6 2

Negative PositiveYes, both positive

and negative

No, only negative

21

In 56% of cases, CRAs also hold information on the number of days that a loan is past due, in addition to any missed payments. Not all CRAs have definitions of a missed payment and many do not have a minimum value amount for missed payments. There is no unified version of the definition in terms of the number of days a payment is past due, but usually it is one month.

Even when the accounts are settled, most of CRAs keep data on them. As Figure 11 shows, more than 70% of CRAs hold data on three types of settled accounts whereas only 37% of CRAs track data on special payment terms for accounts in difficulty.

Figure 11 Loan data held by CRAs

Data processing

The grounds for processing data vary from country to country. Nearly half of the European CRAs obtain default or negative (60 or more days in arrears) data on the basis of ‘specific laws’, unlike in 2015 when the majority of the respondents obtained such data on the basis of ‘legitimate interest’ under the current EU Data Protection Directive (Directive 95/46/EC). It is important to note that more and more CRAs are using ‘specific laws’ rather than ‘legitimate interest’ as the basis for processing of negative data, 12 members confirmed that they use ‘specific law’ as ground for data processing compared to 9 members which use ‘legitimate interest’. In 53% (74% in the 2015 survey) of cases respondents state that it is possible to register that a file is under dispute, as figure 12 shows, and in the majority of cases this is possible for all types of products.

Figure 12 Is it possible to register that a file (contract) is under dispute?

Figure 13 How often credit industry supplied contract information?

In 41% of cases, contract information supplied to CRAs by the credit industry is updated once a month, in 34% of cases it is updated daily, and in 16% − weekly. For publicly supplied data, such as court data, 50% respondents state that such data is updated daily.

22

What types of organisations obtain data from CRAs and the data they access

Among the organisations that obtain data from CRAs in terms of depth and breadth, there are those engaged in the provision of ‘mainstream’ lending products such as banks, leasing companies, credit card suppliers, mortgage providers, retail credit suppliers, and credit unions. These organisations are mostly interested in credit data, such as data on mortgages, consumer loans, credit and retail cards, leasing and credit line on credit accounts. In addition to the data mentioned above, these lenders also use data on utilities, mobile and TV services in order to make better lending decisions. Telecommunication companies, TV providers, and debt collectors are also using CRAs’ services to obtain a wide range of data. Police departments are mostly accessing data supplied by providers of ‘mainstream’ lending products. Central banks access mostly data on consumer loans, credit and store cards as well as data on educational loans for their purposes. Table 8 below provides a detailed overview of the main types of organisations that obtain data from CRAs, and types of data obtained.

Zero CRAs

From 1 to 5 CRAs

From 6 to 10 CRAs

From 11 to 15 CRAs

From 16 to 20 CRAs

More than 21 CRA


Table 8 What types of organisations obtain data from the CRA and the data they access?

Mor

tgag

e

Cons

umer

loan

s

Cred

it an

d st

ore

card

Payd

ay lo

ans/

SMS

loan

s Cr

edit

line

Poin

t of S

ale

cred

it/In

stal

men

tEn

ergy

Hom

e re

nts,

Hea

lth

insu

ranc

e Ed

ucat

ion

loan

s

Fixe

d lin

e Te

leco

ms

Inte

rnet

serv

ice

prov

ider

sM

ail o

rder

Sate

llite/

Cabl

e TV

Tele

com

s - m

obile

Wat

erO

ther

s - p

leas

e de

tail

Banks 27 27 26 10 21 16 6 1 14 2 3 5 2 2 3 5Leasing 20 20 19 13 18 15 6 3 10 7 5 4 5 8 3 8Credit card suppliers 16 17 19 11 14 11 6 3 10 7 5 5 5 7 3 1Mortgage providers 18 15 15 11 15 13 6 3 10 7 5 5 5 8 3 8Retail credit suppliers 15 16 16 12 15 14 6 3 8 7 5 6 5 8 3 7Credit Unions 18 19 17 12 15 13 5 3 10 6 4 5 4 7 2 6Telecommunication companies 10 9 9 6 9 9 6 2 5 8 6 4 5 10 3 6Debt collectors / debt purchasers 10 10 9 9 10 9 6 2 6 6 5 5 5 6 4 5Acquirers of credit portfolios 10 8 9 7 9 9 5 2 6 6 4 6 4 6 4 6Energy (electricity, gas, other fuel) 8 7 7 7 8 7 8 2 5 6 5 4 4 6 3 5Courts 7 6 5 5 7 6 5 2 5 6 4 1 4 6 3 3Police 7 6 6 5 7 6 5 2 6 6 4 2 4 6 3 4Government departments 6 5 6 5 7 6 6 3 5 7 5 2 5 7 3 5Home rental companies 5 5 5 4 5 4 3 4 2 3 3 3 3 3 1 5Internet providers (broadband) 5 5 5 4 5 4 5 2 4 7 7 2 5 6 2 5Other insurers 7 5 5 4 6 5 5 4 4 6 4 2 5 6 3 6Television suppliers 5 5 5 4 5 4 4 3 3 7 4 2 8 7 2 6Water 5 4 4 4 5 4 6 2 4 5 4 2 4 5 5 5Central banks 4 3 3 4 3 2 2 0 3 2 1 1 1 2 2 2Brokers/Intermediaries 3 3 3 1 2 3 3 1 2 2 2 2 2 2 1 4Health insurance 4 3 3 2 4 4 3 4 2 4 2 1 3 4 1 5Payment services providers (PayPal, WU) 3 3 3 2 3 2 3 2 2 3 3 1 3 3 1 5Tax authorities 3 3 3 2 3 3 2 1 3 2 2 2 2 2 1 3Other financial market authorities 2 2 2 2 2 1 2 0 2 2 2 1 2 2 2 2Crowd-funding platforms 2 2 2 1 3 3 2 2 1 2 2 1 2 3 0 6Recruiters 2 1 2 1 2 2 2 1 2 2 1 1 1 2 1 3Investors 2 1 1 1 1 1 1 0 1 2 0 0 0 1 1 3Others 5 5 5 0 4 4 1 2 2 2 1 1 2 3 0 6

23

Services provided by CRAs

Credit application, portfolio monitoring, and identity checking are the most frequently used services by clients of CRAs. Banks, leasing companies, credit card companies, retail credit suppliers, mortgage providers, and credit unions are the most advanced users of CRAs’ services. Providers of utilities (energy and water) and TV and Internet providers use CRAs’ services mostly for credit application, portfolio management, and identity checking purposes. In addition, these organisations also use CRAs’ services to identify new customers. Other clients use CRAs services mainly for identity checking and portfolio monitoring while central banks use data mainly to conduct statistical analysis and make economic forecasts.

Zero CRAs

From 1 to 5 CRAs

From 6 to 10 CRAs

From 11 to 15 CRAs

From 16 to 20 CRAs

More than 21 CRA


Table 9 What type of services do organisations obtain from your CRA?

Cred

it ap

plic

atio

ns

Port

folio

m

onito

ring

Iden

tity

chec

king

Stat

istic

al,

econ

onom

ical

and

ris

k an

alys

isFr

aud

prev

entio

n an

d de

tect

ion

Arre

ars

man

agem

ent

Benc

hmar

king

Colle

ctio

ns

Scre

enin

g cu

stom

ers f

rom

an

exist

ing

list

Debt

or tr

acin

g

Cros

s sel

l / u

p se

ll

Iden

tify

new

cu

stom

ers t

o

Staf

f vet

ting

Paym

ents

pr

oces

sing

Banks 27 27 17 18 16 14 15 12 11 10 9 7 5 2Credit unions 26 26 17 17 15 14 14 12 11 10 8 7 3 2Leasing 25 23 17 17 16 12 13 10 10 9 7 6 4 2Credit card suppliers 22 23 15 15 14 11 13 10 10 9 7 7 4 2Retail credit suppliers 19 19 14 13 13 10 12 8 8 7 5 6 3 2Mortgage providers 20 21 15 14 12 11 13 9 9 9 7 6 3 2Debt collectors/debt purchasers 13 13 10 10 9 8 8 9 5 7 4 4 3 2Telecommunication companies 14 15 13 9 10 8 8 7 7 6 4 6 3 2Television suppliers 11 12 11 8 8 8 7 7 7 6 4 6 3 2Energy 10 12 10 7 7 7 6 6 7 6 4 6 3 2Water 8 9 8 7 7 7 6 7 7 6 4 6 3 2Acquireres of credit portfolios 10 12 10 8 6 5 4 6 4 5 2 3 1 1Other insurances 9 9 10 8 6 5 8 5 6 3 5 6 4 2Payment services providers 6 7 8 6 6 4 3 2 7 3 2 4 1 3Home rental companies 9 8 9 7 7 4 5 4 7 3 4 6 3 1Internet providers 8 9 7 6 4 4 3 4 5 3 2 4 1 1Government departments 7 5 6 5 3 3 3 2 4 2 1 4 1 1Health insurance 6 6 5 5 6 3 6 4 5 2 4 5 3 1Brokers/intermediaries 6 5 4 4 3 2 3 2 3 2 2 3 1 1Police 5 2 4 3 3 2 3 2 2 2 1 2 0 1Courts 5 4 5 4 2 2 3 1 3 1 0 3 1 1Tax authorities 5 4 4 4 2 2 3 2 3 2 2 3 1 1Central banks 2 3 2 5 1 1 2 1 2 1 1 2 1 1Crowd-funding platforms 4 4 4 3 3 1 2 1 2 1 1 2 1 0Data protection authorities 3 1 3 2 2 1 2 1 1 1 0 1 0 1Other financial authorities 2 1 1 1 1 1 1 1 1 1 0 1 0 1Competition authorities 2 1 0 1 1 1 1 1 1 1 1 1 0 1Investors 4 4 4 4 2 0 1 1 1 0 1 1 1 0Other 5 5 3 4 3 2 3 2 2 2 3 2 1 0

24

Social media data In 2017, most of ACCIS members reported the existence of legal obstacles in their jurisdictions preventing the use of social media data for creditworthiness assessment. In only 4 out of the 23 countries covered by the survey the use of social media data for creditworthiness assessment is allowed by law: Russia, the Czech Republic, Slovakia and Hungary (in Hungary the use of social media data is only allowed e with customer consent and with purpose limitation).

Figure 14 Is collection, sharing or usage of social media data for credit worthiness assessment allowed by law in your country?

Figure 15 Social media data

NAYes No

Key findings: • The 2017 survey shows that banks, mortgage companies, leasing companies, credit card and credit

retail suppliers remain the principal sources of data for CRAs (as they were in 2015 and 2012). • Most CRAs hold information on mortgages, consumer loans, and credit and store cards. Utilities

and other services, such as mail order, Internet and TV service, exhibit low coverage by CRAs. Mostly negative data is collected for these categories of data.

• Consistently with the results of the previous surveys in 2012 and 2015, in 2017 the depth of the data on “mainstream" lending products covered by CRAs, such as consumer loans, credit and store cards, mortgages and overdrafts, is the highest in terms of both negative and positive data.

• Credit application, portfolio monitoring, and identity checking are the most frequently used services by clients of CRAs.

• Banks, leasing companies, credit card and retail credit suppliers as well as mortgage providers and credit unions are the most advanced users of CRAs’ services. In some countries, utility companies, TV and Internet providers are starting actively to use data provided by CRAs.

Conclusions: • Utility provider companies have potential for a greater supply of data while they as well could use

services provided by CRAs to a greater extent.

25

In 2017, only one (UCB from Russia) credit bureau collect or use social media data. Only 6% of respondents use other online data, such as browser data, search history data, online surfing behaviour/patterns. However, there is an intention to increase the use of social media data in the credit reference sector: 16% of respondents answered positively on their plans of collecting and using such data.

Consumer access to their data

Access to the credit reference file allows consumers to check the accuracy of information about them and assist them in planning their finances.

The World Bank provides the following guidelines on consumer rights and data protection: “Rules regarding the protection of data subjects/consumers should be clearly defined. At the minimum these rules should include: (i) the right to object to their information being collected for certain purposes and/or used for certain purposes, (ii) the right to be informed on the conditions of collection, processing and distribution of data held about them, (iii) the right to access data held about them periodically at little or no cost, and (iv) the right to challenge accuracy of information about them.”7

The current European Data Protection Directive8 and country-specific regulations outline data supply, processing, and access. When notifying data subjects under the ’legitimate interest’ condition or seeking their consent, the data controller must make it clear what will happen to that data and who might be able to use it. Equally, access to the data follows the same rules and any access must be recorded so that there is an audit trail for the data subject.

90% of the CRAs that have responded to the 2017 Survey have to keep a record each time a file is accessed (e.g. access logs or search footprints). In most cases, it is required by national regulations, and in some countries – by both national and EU regulations. This allows lenders to better understand and analyse the reasons why a consumer’s credit file has been accessed which in turn contributes to better decision-making. The data subjects themselves have the right of access to their data under the Data Protection Directive, and in some countries that right is further strengthened with special rules to make the access easier and faster in the case of credit referencing.

Figure 16 Free access by consumers to their data in previous period

7 The World Bank, “General Principles for Credit Reporting”, 2011. http://siteresources.worldbank.org/FINANCIALSECTOR/Resources/Credit_Reporting_text.pdf 8 Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, Official Journal of the European Union L 281 , 23/11/1995 P. 0031 - 0050.

26

Around two thirds of CRAs provide consumers with free access to their data (69% of respondents in 2017, same as in 2015 and 65% in 2012), for more details see figures 17 and 18. When data access is not free of charge, consumers are charged between 2 and 19 EUR.

Figure 17 How much does it cost consumer to see his/her file?

In addition, in around 44% of cases, CRAs provide consumers with additional possibilities to access their file (e.g. accessing the file more frequently than the number of times allowed for free access). It usually costs up to 10 EUR, however, some options might cost more than 20 EUR.

In most cases CRAs have an obligation to provide a consumer with his/her credit file within a certain number of days. In 19% of cases, the consumer will receive it in a week, in another 19% of cases – in two weeks, and in a 31% of cases – in a month. Only 22% of CRAs who responded to the survey do not have a legal obligation to provide a consumer with his/her file within a certain number of days.

Figure 18 How much does it cost a consumer to see their file?

Figure 19 Do you have an obligation to provide a consumer his file within a certain number of days?

In 2017, each CRA reported that their consumers have the right to access data and consumers are offered to select how they will access their files. As in 2015, most consumers prefer to order their data by post or in person. In addition, the results of the 2017 survey show that the Internet is becoming one of the

27

preferred options for consumers to order/access their files, whereas this option was less popular in 2015 according to the results of the previous survey.

Figure 20 How can consumers get access/receive their file?

In most cases, consumers can receive their file by post (94% of CRAs offer this possibility). Often, they can collect it in person or access it via the Internet. In the majority of cases, a copy of the file is received within two weeks of the request. In 75% of cases, there is right to object to the processing.

Access by consumers to their data enables them to verify the quality and accuracy of the data. In 100% of cases, the consumer has the right to dispute, require rectification and removal of incorrect data. It is free of charge, but in some cases it requires court decisions. In 50% (65% in 2015) of cases, the file is marked “under dispute” for the period of investigation. In most countries this process takes less than two weeks. However, in practice it might take less time and be completed in several business days. In some countries there are no legal requirements and the file can be under investigation until the dispute is settled.

Only in less than a quarter of all cases (22%) a consumer has the right to add comments to his/her file. It is free of charge in all reported cases, see figure 22.

Figure 21 Is there a right to object to the processing? Figure 22 Do consumers have the right to add a comment?

Consumers’ access to their credit file helps them better understand what data is held by CRAs and what affects their credit history. By having a better understanding of how missed payments might impact their credit record, consumers are able to approach their finances with awareness of this potential impact. The number of CRAs that provide educational information materials to help borrowers improve their “financial standing” increased to 63% of the respondents to the survey in 2017, as compared to 58 % in 2015.

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The principle of reciprocity and exceptions to facilitate access

Reciprocity is often a key condition to become a member of the credit referencing systems. It encourages lenders to share data in order to access it. Registering debts and recording credit history not only incentivises borrowers to pay or engage if they are in trouble but also may discourage others from lending to an already indebted borrower. Data shared under the reciprocity principles helps to prevent over-indebtedness, bad debt, fraud, and money laundering, and helps to support debt recovery and debtor tracing, contributing to responsible lending.

Figure 23 Is the credit file marked as “under dispute” during investigation?

Figure 24 Is the credit file marked as “under dispute” during investigation?

Key findings:

§ 69% of consumers have free access to their data, (roughly the same percentage as in 2015); when data access is not free of charge, consumers are charged between 2 and 19 EUR. In most cases CRAs have an obligation to provide a consumer with his/her file within a certain number of days, in half of the cases it is within two weeks.

§ In all cases consumers have the right to access their data. Most CRAs provide an option to order and receive a copy of their credit file by post or in person. The results of the 2017 indicate that the Internet is becoming the preferred way for consumers to order and receive the data about them, in comparison to previous years.

§ In 100% of cases, the consumer has the right to dispute, require rectification and removal of incorrect data free of charge, but in some cases, it requires court decisions. However, only in 22% of cases, the consumer has a right to add comments to his/her file. Situation is less or more the same as in previous years.

§ 63% of CRAs that responded to the survey (as compared to 58% in 2015) provide educational information materials to help borrowers improve their “financial standing”.

Conclusions:

CRAs promote consumers access to their credit file, and this can benefit all stakeholders, and in the other hand huge number of assessment may not be in CRAs best interest

• CRAs will be able to have more correct and complete information about borrowers’ financial stance;

• Consumers will be able to better understand their financial situation and manage it accordingly;

• Lenders/CRAs’ clients will be able to make their decisions based on more complete and correct

• information about their borrowers/consumers.

29

The 2017 survey showed that in 72% (as compared to 79% in 2015) of cases, data is shared and accessed under a reciprocal basis. It further showed that in 38% of cases, there are some exceptions or dispensations from the reciprocity rule.

10 respondents reported that there are closed user groups for their clients, i.e. groups of clients providing data that is only accessible to members of this group.

Only 10% of members that responded to the survey have confirmed that shared data can be used for assessing securitisation books, and 31% of responders confirmed that new lenders, such as FinTech credit granters can access and use data to access the credit risk of potential customers.

For a detailed description of regulations on access to data, please refer to Table 39 in Annex VI.

Even though brokers and intermediaries are generally not the providers of data, given that they are not direct lenders, in 2017, in 34% of cases, they could access and use data on behalf of members of the database, and in 16% of cases, they had some access for their own purposes, such as deciding to which lender to send business to. In the latter case, this data might be restricted to data from public sources rather than the data supplied by lenders. In 2015, figures on access by brokers and intermediaries were 28% and 21% respectively.

Figure 25 Is data shared under reciprocal basis?

Figure 26 Are there any exceptions or dispensations to the reciprocity rules?

Figure 27 May brokers or intermediaries access or use data only on behalf of the members of the database?

Figure 28 Are intermediaries able to access and use data for their own purpose?

30

Figure 29 Is data shared under reciprocal basis

Figure 30 Is the principle of reciprocity mandated by law?

In addition to the rules on accessing data such as reciprocity, there are also some exceptions to facilitate access such as for law enforcement and government bodies. 47% of the respondents indicated that in their countries government departments, including central banks, have access to data held by CRAs for monitoring and economic policy purposes, see figure 33. For instance, some government departments (i.e. Tax Authorities) and Law Enforcement agencies (i.e. Police) are allowed access as an exception to the reciprocity rule. In Italy, there is an exception from the reciprocity rule allowing telecommunication companies, insurance companies, and TV companies (Art 6 bis, Decree 138, 13 August 2011) to access credit bureaus data without sharing their data. However, Law 4 August 2017, no. 124 - besides having the effect of including companies authorize to sell electricity and natural gas to end-users among the subjects that can access credit bureaus - establishes that access by these and the previously mentioned subjects can occur also within a reciprocity framework, under certain conditions. In only 9% of the responses, data available for assessing lending portfolios.

Yes No NAYes No

Figure 31 Brokers and intermediaries access and use data on behalf of membership in previous period

Figure 32 Intermediaries accessibility and usage of data for their own purpose in previous period

31

Figure 33 Can governments or central banks use data for monitoring and macroeconomic policy purposes?

Figure 34 Securitisation - can shared data be used for assessing securitisation books?

Process and Quality Control

World Bank General Principle 2 states: “Credit reporting systems should have rigorous standards of security and reliability, and be efficient”.9

In 2017, 72% of respondents (compared to 55% in 2015) noted that they have mechanisms in place to secure purpose limitation for the use of consumers' data shared by them. In most cases, contractual obligations or laws regulate the purpose of data usage. Sometimes CRAs use independent audit and compliance monitoring as well as self-disclosure and quality assurance mechanisms.

9 The World Bank, “General Principles for Credit Reporting”, 2011, p. 3.

Key Findings:

§ In 72% (79% in 2015) of cases, data is shared and accessed under a reciprocal basis, and in 38% (41% in 2015) of cases, there are some exceptions or dispensations from the reciprocity rule.

§ In 31 % of cases, there are closed user groups of clients which provide data that is only accessible to members of these groups, as compared to 34 % of responses in 2015.

§ In 34% (28% in 2015) of cases, intermediaries or brokers may access and use data on behalf of members of the database, but only 16% can use it for their own purposes.

§ 47% of CRAs stated that governments and central banks in their countries have access to their data, with purpose of monitoring and creating economic policy.

§ Only 9% of respondents reported that data are available for assessing securitised lending portfolios.

§ 3 out of 32 CRAs have confirmed that shared data can be used for assessing securitisation books.

Conclusions:

§ Access to data for better evaluation and monitoring of securitised debt could be improved to support the reinvigoration of the securitisation market.

32

In 19% of responses to the 2017 survey, the data held by CRAs is subject to independent audit for data quality purposes, which is a significant increase by 18 percentage points compared to 2015 (41%). 52% of members who responded to the survey comply with special standards - mostly the ISO9001 for “Quality Management Systems", ISO27000 and ISO27001 for “Information Technology, Security Techniques and Information Security Management Systems” or internal guidelines. Some CRAs comply with ISO 22301. See Annex V for a detailed description of special standards that individual credit reporting agencies comply with.

To manage data quality, CRAs implement stringent controls and data requirements. Most CRAs usually check data each time it is received for loading and before clients are accepted to the database. All CRAs use regulatory complaints (e.g. complaints by data protection authorities), and all of them use consumer complaints to manage data quality. 18 out of 32 members who responded to the survey crosscheck data with other files to ensure data quality.

75% of CRAs declare that automatic credit scoring is allowed by law and same number of CRAs confirmed that they use automatic credit scoring for clients creditworthiness.

Figure 35 Does your credit bureau have a mechanism in place to secure purpose limitation?

Figure 36 Is the data subject to an independent audit for data quality purposes?

Figure 37 Is the data subject to an independent audit for data quality purposes?

Figure 38 Do you comply with special standards (e.g. ISO or others)?

33

Figure 39 How does your bureau manage data quality?

Key Findings:

§ 72% of respondents confirmed that they have mechanisms in place to secure purpose limitation. § In 59% of cases, the data is subject to independent audit for data quality purposes. § 50% of members who responded to the survey comply with industry recognized standards.

34

3. Legal and regulatory environment General Principle 4 of the World Bank's General Principles states that “the overall legal and regulatory framework for credit reporting should be clear, predictable, non-discriminatory, proportionate and supportive of data subject and consumer rights. The legal and regulatory framework should include effective judicial or extrajudicial dispute resolution mechanisms”10.

In their responses to the 2017 survey, 20 ACCIS members from 17 European countries reported that data sharing was required by regulation. In the results of the 2015 Survey, sharing of credit data was required by regulation in 13 cases. On the other hand, in 2017, sharing of non-credit data was required only in 7 cases. It is worth noting that in most cases regulations requiring data sharing are specifically regulating credit-reporting activities. Only in a few cases, it is regulated by general banking laws. Please refer to Table 42 in Annex VI for a detailed description.

10 The World Bank, “General Principles for Credit Reporting”, 2011, p. 3.

Figure 40 Is there regulation requiring the sharing of credit data?

*Austrian CRAs provided different answers, Polish CRAs provided different answers due to different legal grounds and different scope of activities

Figure 41 Number of CRAs which have confirmed existence of regulation which requires credit data sharing

Yes No

35

Figure 42 Is there a regulation requiring the sharing of credit data?

Figure 43 Is there regulation requiring the sharing of non-credit data?

47% of lenders (31% in 2015) have a legal obligation to consult credit reporting databases.

In 2017, in 22% of cases, (Austria, Belgium, Cyprus, Finland, Germany and in the UK) the access to public/court data is required by regulations, while in 63% it is permitted, and in 22% it is not allowed. Please refer to Table 46 in Annex VI for details.

Legislative barriers restricting the sharing of consumer accounts and limiting the depth of data from those accounts still exist – 38 % of the respondents in 2017 reported the existence of such barriers. However, the share of respondents who stated that there is data in existing client portfolios that could not be provided for legal reasons has decreased from 69% in 2015. Figure 48 shows in which countries these barriers are reported. It should also be noted that there are many portfolios that are not shared at all.

Figure 44 Do lenders have a legal obligation to consult CRAs?

Figure 45 Is access to public/court data required by regulation?

Figure 46 Is access to public/court data permitted by regulation?

Figure 47 Is there data in client portfolios that cannot be provided for legal reasons?

36

Figure 48 Is there data in clients' portfolios that cannot be provided for legal reasons?

Figure 49 Is there any other law or regulation that restrict data sharing?

See Tables 39 and 40 in Annex VI for details on national legislation/regulation which may affect the credit reporting industry and if there are other laws or regulations that restrict data sharing.

Tables 35 and 36 of Annex VI tell more on specific legislation on credit reporting in their countries and on sectorial supervision.

NAYes No

Key findings:

§ 47% of lenders (31% in 2015) have a legal obligation to consult credit reporting databases. § Sharing of credit data is required by regulation in 63% of cases; non-credit data in 22%, comparing to

41% and 17% in 2015. § In 22% of cases, the access to public/court data is required by regulations and in 63% it is permitted. § Legislative barriers restricting the sharing of consumer accounts and the depth of data from those

accounts still exist in 38% of cases. 31% of respondents stated there are other laws or regulations that restrict data sharing, comparing to 41% in 2015.

§ It is important to indicate that the number of respondents which confirmed legislative barriers existence has dropped from 69% to 38%.

Conclusions:

§ Restrictive or unclear regulation as e.g. uncertainties in the reading of the upcoming GDPR is still a main constraint, even if there is improvement since previous survey, for data sharing among ACCIS European members. Data Protection regulation was stated as the main regulatory obstacle that CRAs face at both national and EU levels. There is room to improve the regulation in order to make it more clear and supportive for credit reporting agencies.

§

37

4. Cross-border data flows The World Bank states: “As financial markets are increasingly globalised, cross-border data transfers can become a useful instrument to monitor the credit exposures of important borrowers outside a financial institution’s home market, or to facilitate the provision of credit and other financial services across borders (e.g. to individuals that do not have a credit history in the country where they are applying for credit). In addition, a single mechanism serving more than one country can be the only cost-effective option for credit reporting activities to develop in some small markets. While in principle cross-border data flows raise similar concerns as purely domestic credit reporting activities, cross-border activities typically face a more complex environment due to the multiplicity of applicable laws, consumer protection frameworks, credit cultures, market practices, and institutional structures, among others. General Principle 5 is, therefore, that cross-border credit data transfers should be facilitated, where appropriate, provided that adequate requirements are in place.”11

Based on the responses to the 2017 Survey, the situation with cross-border data sharing has remained largely the same as in 2015.

In 2017, 37% of members share data with bureaus in other countries, and 31% of members have an access to data from bureau in other countries, for a breakdown on this data see figures 50 and 51. Those who share data indicated data protection laws and private agreements based on ACCIS template as a legal basis for cross-border data sharing. Please refer to Annex VII for detailed description by CRAs.

The sharing of data directly with financial institutions in other countries remains limited. In 78% of cases, it does not occur at all. Only 16% of European members who responded to the survey share data with financial institutions in other countries, see figures 52 and 53.

11 The World Bank, “General Principles for Credit Reporting”, 2011, p. 4

Figure 50 Does your bureau share data with bureaus in other countries?

Figure 51 Does your bureau have access to data from bureaus in other countries?

38

Figure 52 Does your credit bureau share data with financial institutions in other countries?

Figure 53 Does your bureau have direct access to data from financial institutions in other countries?

Figure 54 Bureaus which have shared data with bureaus in other countries

Key findings: § 37% of respondents share data across borders. § Around 63% of the credit reporting agencies that do not share data indicated a lack of

demand or interest for cross-border data sharing.

§ Only 16% of European members who responded to the survey share data directly with financial institutions in other countries.

§ Situation in cross border data sharing does not show any significant changes since 2012.

Conclusions: § Lack of demand and restrictive or unclear regulatory framework are main obstacles of

cross-border data sharing. More precise and clear legislation would facilitate cross border data sharing.

39

5. Consumer groups’ support for data sharing 52% of respondents reported that consumer groups in their countries support data sharing (in 2012 and in 2015 this percentage was, respectively, 43 % and 59 %).

In most cases (94 %) where consumer groups support data sharing, such support extends to both positive and negative data. In 2017, data privacy and security remain the key concerns. These were the main concerns also in 2015, according to the results of the previous survey.

Figure 55 Share of consumer groups in European countries supporting data sharing

Figure 56 Do consumers group in your country support data sharing?

Figure 57 If yes, does data sharing include full data?

Figure 58 Do you have regular contact with consumer groups?

Key findings:

§ The results of the survey indicate that the consumer groups' support to data sharing seems to be decreasing. 50 % of the respondents reported that such support exists in their country, as compared to 59 % in 2015.

§ Data privacy and data security remain key concerns of consumer groups.

Conclusions:

§ Even though a definite correlation cannot be established between regular contacts with consumer groups and support for data sharing, such regular contacts with the intent to explain the purpose of credit reporting and its benefits might increase the level of support for data sharing further and eliminate key concerns of consumer groups about data privacy and data security.

40

ANNEXES

41

Annex I. What data is available at each CRA

Table 10 What data is held or accessed by credit reference agency database

AT AT BE HR CY CZ CZ DK FU DE DE EL HU IS IT IT PL PL XK RO RU RS ES ES SK SW SW CH NL UK UK UK

CRIF

KSV1

870

BNB

HROK

Arte

mis

SOLU

SCR

IFEx

peria

nSu

omen

Cred

itref

orm

SCHU

FATir

esias

BISZ

Cred

itinf

oCR

IFEx

peria

nBI

KER

IFCB

RKBD

C S.

A.UC

BAS

BEx

peria

nEq

uifa

xCR

IFUC

AB

Cred

itsaf

eCR

IFBK

REx

peria

nEq

uifa

xCa

llcre

dit

Name ## ## ## ## ## ## ## ## ## ## ## ## ## ## ## ## 1 1 ## ## ## ## ## ## ## ## ## ## ## ## 1 ##Othe or previous name ## ## ## ## ## ## ## ## ## ## ## 1 ## ## ## ## ## ## ## ## ## ##Taxpayer ## 1 ## 1 ## 1 1 1 ## ## ## 1 1 1 ## 1 ## ## ## ##Date of birth ## 1 1 ## 1 ## 1 1 1 1 1 1 ## ## ## 1 1 1 1 ## 1 1 ## ## ## ## 1 1 1 ## 1Place of birth ## 1 ## 1 1 1 1 ## ## ## 1 1 ## 1 1 1Gender ## 1 1 1 ## 1 1 1 1 1 ## ## ## 1 1 1 1 ## 1 1 1 1 1 ## 1Addresses ## 1 1 1 1 ## 1 1 1 1 1 1 ## ## ## 1 1 1 1 ## 1 1 1 1 1 1 1 1 1 ## 1Family group data ## 1 ## 1 1 1 1 1 1 ##Others 1 1 1 1 ## 1 1 1 1

Employer identity 1 1 1 1 1Income 1 1 1 1 1 1 1 1 1Assets 1 1 1 1 1 1 ##

Bankruptcy/Incolvency data 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 ## 1Court judgments 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 ## 1

Consumer/borrower public insolvency and court data

Consumer/borrower income and asset data

Consumer/borrower identity data

Data is held in or accessed by credit reference agency database

42

Table 11 Is there a threshold amount below which data is not collected?

Is there a threshold amount for initial data entry below which data is not collected? If yes, specify the amount

Is there a threshold amount below which data is not collected for arrears?

Does it differ by product

AT CRIF Yes 20 EUR

AT KSV1870 Yes 300 EUR

BE BNB Yes 200 € 25 €

HR HROK No

No CY Artemis No

No

CZ SOLUS No

CZK 500

CZ CRIF No

No DK Experian Yes 1000 DKK open remark, 250

DKK closed remark 1000 DKK open remark, 250 DKK closed remark

FU Suomen No

DE Creditreform No

No DE SCHUFA Yes 50 EUR for non-bank clients,

100 EUR for bank clients

EL Tiresias NA

€ 20

HU BISZ

Only in case of Pawn Brokering credit type, above HUF 300.000

HUF 127.500 (minimum wage)

IS CREDITINFO Yes 50.000 isk kr 50.000 isk kr

IT CRIF No

No IT Experian No

No

PL BIK No

No PL ERIF No

consumer - 200 company - 500

XK CBRK No

RO BDC S.A. No

30 RON

RU UCB No

No RS ASB No

No

ES Experian NA

ES Equifax No SK CRIF No No SW UC AB No 100SEK No SW Creditsafe NA CH CRIF No NL BKR Yes Yes, Euro 250 No UK Experian No No UK Equifax No UK Callcredit No No

43

Annex II. Organisations that supply data to the CRAs

Table 12 What types of organisations supply data to the CRAs?

AT AT BE HR CY CZ CZ DK FI DE DE EL HU IS IT IT PL PL XK RO RU RS ES ES SK SWSWCH NL UK UK UK

CRIF

KSV1

870

BNB

HRO

KAr

tem

isSO

LUS

CRIF

Expe

rian

Suom

enCr

editr

efor

mSC

HUFA

Tire

sias

BISZ

Cred

itinf

oCR

IFEx

peria

nBI

KER

IFCB

RKBD

C S.

A.UC

BAS

BEx

peria

nEq

uifa

xCR

IFUC

AB

Cred

itsaf

eCR

IFBK

REx

peria

nEq

uifa

xCa

llcre

dit

Banks ## 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1Credit unions ## 1 1 1 ## 1 1 1 1 1 1 1 1 1 ## 1 1 1 1 1 1 1Debt collectors / debt purchasers 1 ## 1 ## 1 1 1 1 1 1 ## 1 ## 1 1 1 1 1 1Leasing 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 ## 1 1 1 DP 1 1 1 1 1Credit card suppliers 1 1 1 1 1 ## 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1Retail credit suppliers 1 ## 1 1 1 1 1 1 1 1 1 1 1 ## ## 1 1 1 1 1 1 1Health insurance ## ## ## 1 1 1 ## ## ## 1 ##Other insurers ## ## ## 1 1 1 1 DP DP 1 1 ## ## ## 1 1 1 1 1Energy 1 ## 1 ## 1 1 1 1 DP DP 1 ## 1 ## 1 1 1 1 1 1Water ## ## ## 1 1 1 1 1 ## 1 ## 1 1 1 1 1Telecommunication companies 1 ## DP 1 ## 1 1 1 1 DP DP 1 ## 1 DP 1 1 1 1 1 1 1Television suppliers 1 ## DP 1 1 1 DP DP 1 ## ## ## 1 1 1 1Internet providers 1 ## 1 ## 1 1 1 1 1 ## ## ## 1 1 1 1Mortgage providers ## ## 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 ## 1 1 1 1 1 1 1 1Home rental companies 1 ## ## 1 1 1 1 ## ## ## 1 1 1 1 1Brokers/Intermediaries ## ## ## 1 1 1 ## ## ## 1 1 1 1 1Courts ## ## ## ## 1 1 1 1 1 1 1 ## ## ## 1 1 1 1 1 1 1Government departments ## ## 1 1 ## ## 1 1 1 1 1 ## ## ## 1 1 1 1 1 1Crowd-funding platforms ## ## ## 1 1 ## ## ## DP 1 ##Payment services providers 1 ## ## 1 1 1 1 ## ## ## 1 1 1 1 ##Tax authorities ## ## ## ## 1 ## 1 ## ## ## 1 1 1 1 1Police ## ## ## ## ## 1 ## ## ## 1 1Central banks ## ## 1 ## ## ## ## ## ## 1Acquirers of credit portfolios ## ## 1 ## 1 1 1 1 ## 1 ## 1 1 1 1 1 1 1Investors ## ## ## 1 ## ## ## ## ##Others ## ## 1 ## ## 1 ## ## ## ## 1 ## ## ## ## 1 ## ## 1 ## ## ##Execution authorities 1 1Consumer credit providers 1Building societis 1Credit guarantee Debt assistance organisations for consumers 1

Yes, organisations supply data to CRA

No, organisations doesn't supply data to CRA

In discussion

Not answered

44

Annex III. Product coverage (by CRA)

Table 13 Do you hold data for these products?

AT

AT

BE HR CY CZ CZ DK FI DE

DE EL HU IS IT IT PL PL XK RO RU RS ES ES SK SW SW CH NL

UK

UK

UK

CRIF

KSV1

870

BNB

HRO

K

Art

emis

CRIF

SOLU

S

Expe

rian

Suom

en

Cred

itre

form

SCH

UFA

Tire

sias

BISZ

CRED

ITIN

FO

CRIF

Expe

rian

BIK

ERIF

CBRK

BDC

S.A

.

UCB

ASB

Equi

fax

Expe

rian

CRIF

Cred

itsa

fe

UC

AB

CRIF

BKR

Callc

redi

t

Equi

fax

Expe

rian

Mortgage 2 1 1 1 1 1 1 2 0 1 1 1 1 1 1 1 1 1 1 1 1 1 0 0 1 0 1 1 0 1 1 1

Consumer Loans 2 1 1 1 1 1 1 1 0 1 1 1 1 1 1 1 1 1 1 1 1 1 1 0 1 0 1 1 1 1 1 1

Credit and store card 2 1 1 1 1 1 1 1 0 1 1 1 1 1 1 1 1 1 1 1 1 1 1 0 1 0 1 1 1 1 1 1

Mail order 22 2 1 2 2 0 0 1 0 0 1 2 0 0 5 2 2 0 0 2 2 2 0 0 0 0 1 8 1 1 1

Point of sale credit 2 1 1 1 2 1 1 1 0 0 1 2 1 0 5 2 2 0 0 2 1 2 0 0 1 0 0 1 1 1 0 1

Energy (gas, electricity, oil) 2 2 5 2 2 0 0 1 0 0 1 2 0 1 5 2 2 1 0 2 0 2 1 0 0 0 1 8 1 1 1

Water 2 2 5 2 2 0 0 1 0 0 0 2 0 1 5 2 2 1 2 2 0 2 1 0 0 0 1 8 0 1 1

Education loans 2 2 1 1 1 0 1 0 0 1 0 1 1 1 1 1 1 0 0 2 1 2 0 0 0 0 5 8 1 1 1

Credit line on a current account 2 1 1 1 1 1 1 1 0 1 1 1 1 1 1 1 1 1 1 1 1 1 0 0 0 0 1 1 1 1 1

Internet service provider 2 2 5 2 2 0 1 1 0 0 1 2 0 1 5 2 2 1 0 2 0 2 1 0 0 0 1 8 0 1 0

Satellite/cable TV 2 2 5 2 2 0 0 1 0 0 0 2 0 1 5 2 2 1 0 2 0 2 0 0 0 0 1 8 0 1 1

Fixed line Telecoms* 2 2 5 2 2 0 1 1 0 0 1 2 0 1 5 2 2 1 0 2 0 2 1 0 0 0 1 8 0 1 1

Telecoms - mobile 22 2 5 2 2 0 1 1 0 0 1 2 0 1 5 1 2 1 0 2 0 2 1 0 0 0 1 1 1 1 1

Payday loans/SMS loans 2 2 ## 2 2 1 1 1 0 1 2 1 1 1 5 2 1 1 0 2 1 2 1 1 1 0 1 0 8 1 1 1

Home rent 2 2 5 2 2 0 0 1 0 0 0 2 0 0 5 2 2 1 0 2 0 2 0 0 0 0 0 8 0 0 1

Leasing 2 1 5 1 1 1 0 1 0 0 1 1 1 0 1 2 1 1 1 2 0 2 0 0 1 0 0 0 1 0 1 1

Health insurance 2 2 5 2 2 0 0 1 0 0 2 2 0 0 5 2 2 0 0 2 0 2 1 0 0 0 0 8 0 0 0

Other insurances 2 2 5 2 2 0 0 1 0 0 0 2 0 0 5 2 2 1 1 2 0 2 1 0 0 0 1 8 0 0 1

Others 2 2 5 1 2 1 0 2 0 2 1 2 1 2 5 2 2 2 0 2 2 2 1 0 1 0 2 1 1 2 2

45

Annex IV. Depth of data by product

Table 14 Depth of data: Mortgage

Defa

ult (

>3 m

onth

)

In a

rrea

rs (1

-3 m

onth

s)

Reje

cted

cheq

ue lis

t

Num

ber o

f miss

ed p

aym

ents

Writ

e-of

fs

Orig

inal

cont

ract

am

ount

Out

stan

ding

am

ount

Paym

ent t

erm

s

inte

rest

rate

Dura

tion

of lo

an

On

time

paym

ent

AT CRIFAT KSV1870 1 1 1 1 1BE BNB 1 1 1 1HR HROK 1 1 1 1 1 1 1 1CY Artemis 1 1 1 1 1 1 1CZ CRIF 1 1 1 1 1 1 1 1CZ SOLUS 1 1 1 1 1 1 1 1 1DK ExperianFI SuomenDE Creditreform 1 1 1 1 1 1 1DE SCHUFA 1 1 1EL Tiresias 1 1 1 1 1 1 1HU BISZ 1 1 1 1 1 1IS CREDITINFO 1 1 1 1IT CRIF 1 1 1 1 1 1 1 1 1IT Experian 1 1 1 1 1 1 1 1 1PL BIK 1 1 1 1 1 1 1 1 1 1PL ERIF 1 1 1 1XK CBRK 1 1 1 1 1 1 1 1 1RO BDC S.A. 1 1 1 1 1 1 1 1 1RU UCB 1 1 1 1 1 1 1 1 1RS ASB 1 1 1 1 1ES Equifax 1 1ES Experian 1 1 1SK CRIF 1 1 1 1 1 1 1 1 1SW CreditsafeSW UC AB 1 1 1 1CH CRIF 1NL BKR 1 1UK Callcredit 1 1 1 1 1 1 1 1 1UK Equifax 1 1 1 1 1 1 1 1 1UK Experian 1 1 1 1 1 1 1 1 1

Negative PositiveMortgage

1 CRA holds this type of data for this product

46

Table 15 Depth of data: Consumer Loans

Defa

ult (

>3 m

onth

)

In a

rrea

rs (1

-3 m

onth

s)

Reje

cted

cheq

ue lis

t

Num

ber o

f miss

ed p

aym

ents

Writ

e-of

fs

Orig

inal

cont

ract

am

ount

Out

stan

ding

am

ount

Paym

ent t

erm

s

inte

rest

rate

Dura

tion

of lo

an

On

time

paym

ent

AT CRIF 1 1AT KSV1870 1 1 1 1 1BE BNB 1 1 1 1HR HROK 1 1 1 1 1 1 1 1CY Artemis 1 1 1 1 1 1 1CZ CRIF 1 1 1 1 1 1 1 1 1CZ SOLUS 1 1 1 1 1 1 1 1 1DK ExperianFI SuomenDE Creditreform 1 1 1 1 1 1 1 1DE SCHUFA 1 1 1 1 1 1EL Tiresias 1 1 1 1 1 1 1HU BISZ 1 1 1 1 1 1IS CREDITINFO 1 1 1 1IT CRIF 1 1 1 1 1 1 1 1 1IT Experian 1 1 1 1 1 1 1 1 1PL BIK 1 1 1 1 1 1 1 1 1 1PL ERIF 1 1 1 1XK CBRK 1 1 1 1 1 1 1 1 1RO BDC S.A. 1 1 1 1 1 1 1 1 1RU UCB 1 1 1 1 1 1 1 1 1 1RS ASB 1 1 1 1 1ES Equifax 1 1 1 1 1 1ES Experian 1 1 1SK CRIF 1 1 1 1 1 1 1 1 1SW CreditsafeSW UC AB 1 1 1 1CH CRIF 1NL BKR 1 1 1 1UK Callcredit 1 1 1 1 1 1 1 1 1UK Equifax 1 1 1 1 1 1 1 1 1UK Experian 1 1 1 1 1 1 1 1 1

Negative PositiveConsumer loans


47

Table 16 Depth of data: Credit and store cards

Defa

ult (

>3 m

onth

)

In a

rrea

rs (1

-3 m

onth

s)

Reje

cted

cheq

ue lis

t

Num

ber o

f miss

ed p

aym

ents

Writ

e-of

fs

Orig

inal

cont

ract

am

ount

Out

stan

ding

am

ount

Paym

ent t

erm

s

inte

rest

rate

Dura

tion

of lo

an

On

time

paym

ent

AT CRIF 1 1AT KSV1870 1 1 1 1 1BE BNB 1 1 1 1HR HROK 1 1 1 1 1 1 1 1CY Artemis 1 1 1 1 1 1 1CZ CRIF 1 1 1 1 1 1 1 1 1CZ SOLUS 1 1 1 1 1 1 1 1 1DK ExperianFI SuomenDE Creditreform 1 1 1 1 1 1DE SCHUFA 1 1 1EL Tiresias 1 1 1 1 1 1 1HU BISZ 1 1 1 1 1 1IS CREDITINFO 1 1 1 1IT CRIF 1 1 1 1 1 1 1 1 1IT Experian 1 1 1 1 1 1 1 1 1PL BIK 1 1 1 1 1 1 1 1 1 1PL ERIF 1 1 1 1XK CBRK 1 1 1 1 1 1 1 1 1RO BDC S.A. 1 1 1 1 1 1 1 1 1RU UCB 1 1 1 1 1 1 1 1 1 1RS ASB 1 1 1 1 1ES Equifax 1 1ES Experian 1 1 1SK CRIF 1 1 1 1 1 1 1 1 1SW CreditsafeSW UC AB 1 1 1 1CH CRIF 1 1NL BKR 1 1 1 1UK Callcredit 1 1 1 1 1 1 1 1 1UK Equifax 1 1 1 1 1 1 1 1 1UK Experian 1 1 1 1 1 1 1 1 1

Negative PositiveCredit and store cards


48

Table 17 Depth of data: Mail order

Defa

ult (

>3 m

onth

)

In a

rrea

rs (1

-3 m

onth

s)

Reje

cted

cheq

ue lis

t

Num

ber o

f miss

ed p

aym

ents

Writ

e-of

fs

Orig

inal

cont

ract

am

ount

Out

stan

ding

am

ount

Paym

ent t

erm

s

inte

rest

rate

Dura

tion

of lo

an

On

time

paym

ent

AT CRIF 1 1AT KSV1870 BE BNB 1 1 1HR HROKCY ArtemisCZ CRIFCZ SOLUSDK ExperianFI SuomenDE Creditreform 1DE SCHUFA 1 1EL TiresiasHU BISZIS CREDITINFOIT CRIFIT ExperianPL BIKPL ERIFXK CBRKRO BDC S.A.RU UCBRS ASBES EquifaxES Experian 1 1 1SK CRIFSW CreditsafeSW UC ABCH CRIF 1 1 1 1NL BKRUK Callcredit 1 1 1 1 1 1 1 1 1UK Equifax 1 1 1 1 1 1 1 1 1UK Experian 1 1 1 1 1 1 1 1 1

Negative PositiveMail order


49

Table 18 Depth of data: Point of sale credit

defa

ult (

>3 m

onth

)

in a

rrea

rs (1

-3 m

onth

s)

reje

cted

cheq

ue lis

t

num

ber o

f miss

ed p

aym

ents

writ

e-of

fs

Orig

inal

cont

ract

am

ount

Out

stan

ding

am

ount

Paym

ent t

erm

s

inte

rest

rate

Dura

tion

of lo

an

On

time

paym

ent

AT CRIF 1 1AT KSV1870 1 1 1 1 1BE BNB 1 1 1 1HR HROK 1 1 1 1 1 1 1 1CY ArtemisCZ CRIF 1 1 1 1 1 1 1 1 1CZ SOLUS 1 1 1 1 1 1 1 1 1DK ExperianFI SuomenDE Creditreform 1 1 1 1 1 1 1 1DE SCHUFA 1 1 1 1 1EL TiresiasHU BISZ 1 1 1 1 1 1IS CREDITINFOIT CRIFIT ExperianPL BIK 1 1 1 1 1 1 1 1 1 1PL ERIFXK CBRKRO BDC S.A.RU UCB 1 1 1 1 1 1 1 1 1RS ASBES EquifaxES Experian 1 1 1SK CRIF 1 1 1 1 1 1 1 1 1SW CreditsafeSW UC ABCH CRIF 1 1NL BKR 1 1 1 1UK Callcredit 1 1 1 1 1 1 1 1 1UK Equifax 1 1 1 1 1 1 1 1 1UK Experian 1 1 1 1 1 1 1 1 1

Negative Positive


50

Table 19 Depth of data: Energy (gas, electricity, oil)

defa

ult (

>3 m

onth

)

in a

rrea

rs (1

-3 m

onth

s)

reje

cted

cheq

ue lis

t

num

ber o

f miss

ed p

aym

ents

writ

e-of

fs

Orig

inal

cont

ract

am

ount

Out

stan

ding

am

ount

Paym

ent t

erm

s

inte

rest

rate

Dura

tion

of lo

an

On

time

paym

ent

AT CRIF 1 1AT KSV1870 BE BNBHR HROKCY ArtemisCZ CRIFCZ SOLUS 1 1DK ExperianFI SuomenDE Creditreform 1DE SCHUFA 1 1 1EL TiresiasHU BISZIS CREDITINFO 1IT CRIFIT ExperianPL BIKPL ERIF 1 1 1 1XK CBRKRO BDC S.A.RU UCBRS ASBES Equifax 1ES Experian 1 1 1SK CRIFSW CreditsafeSW UC ABCH CRIF 1 1NL BKRUK Callcredit 1 1 1 1 1 1 1UK Equifax 1 1 1 1 1 1 1UK Experian 1 1 1 1 1 1 1 1

Negative PositiveEnergy (gas, electricity, oil)

51

Table 20 Depth of data: Water

defa

ult (

>3 m

onth

)

in a

rrea

rs (1

-3 m

onth

s)

reje

cted

cheq

ue lis

t

num

ber o

f miss

ed p

aym

ents

writ

e-of

fs

Orig

inal

cont

ract

am

ount

Out

stan

ding

am

ount

Paym

ent t

erm

s

inte

rest

rate

Dura

tion

of lo

an

On

time

paym

ent

AT CRIFAT KSV1870 BE BNBHR HROKCY ArtemisCZ CRIFCZ SOLUSDK ExperianFI SuomenDE Creditreform 1DE SCHUFA 1 1EL TiresiasHU BISZIS CREDITINFO 1IT CRIFIT ExperianPL BIKPL ERIF 1 1 1 1XK CBRKRO BDC S.A.RU UCBRS ASBES Equifax 1ES Experian 1 1 1SK CRIFSW CreditsafeSW UC ABCH CRIF 1NL BKRUK CallcreditUK Equifax 1 1 1 1 1 1 1 1 1UK Experian 1 1 1 1 1 1 1 1 1

Negative PositiveWater

52

Table 21 Depth of data: Education loans

Defa

ult (

>3 m

onth

)

In a

rrea

rs (1

-3 m

onth

s)

Reje

cted

cheq

ue lis

t

Num

ber o

f miss

ed p

aym

ents

Writ

e-of

fs

Orig

inal

cont

ract

am

ount

Out

stan

ding

am

ount

Paym

ent t

erm

s

inte

rest

rate

Dura

tion

of lo

an

On

time

paym

ent

AT CRIFAT KSV1870 BE BNB 1 1 1 1HR HROK 1 1 1 1 1 1 1 1CY Artemis 1 1 1 1 1 1 1CZ CRIFCZ SOLUS 1 1 1 1 1 1 1 1 1DK ExperianFI SuomenDE Creditreform 1 1 1 1 1 1 1 1DE SCHUFAEL Tiresias 1 1 1 1 1 1 1HU BISZ 1 1 1 1 1 1IS CREDITINFO 1 1 1 1IT CRIF 1 1 1 1 1 1 1 1 1IT Experian 1 1 1 1 1 1 1 1 1 1PL BIK 1 1 1 1 1 1 1 1 1PL ERIFXK CBRKRO BDC S.A.RU UCB 1 1 1 1 1 1 1 1 1RS ASBES EquifaxES Experian 1 1 1SK CRIFSW CreditsafeSW UC ABCH CRIFNL BKRUK Callcredit 1 1 1 1UK Equifax 1 1 1 1 1 1 1 1 1UK Experian 1 1 1 1 1 1 1 1 1

Negative PositiveEducation loans

53

Table 22 Depth of data: Credit line on current account (Overdraft)

defa

ult (

>3 m

onth

)

in a

rrea

rs (1

-3 m

onth

s)

reje

cted

cheq

ue lis

t

num

ber o

f miss

ed p

aym

ents

writ

e-of

fs

Orig

inal

cont

ract

am

ount

Out

stan

ding

am

ount

Paym

ent t

erm

s

inte

rest

rate

Dura

tion

of lo

an

On

time

paym

ent

AT CRIFAT KSV1870 1 1 1 1 1BE BNB 1 1 1 1HR HROK 1 1 1 1 1 1 1 1CY Artemis 1 1 1 1 1 1 1 1CZ CRIF 1 1 1 1 1 1CZ SOLUS 1 1 1 1 1 1 1 1 1DK ExperianFI SuomenDE Creditreform 1 1 1 1 1 1 1 1DE SCHUFA 1 1 1EL Tiresias 1 1 1 1 1 1 1HU BISZ 1 1 1 1 1 1IS CREDITINFO 1IT CRIF 1 1 1 1 1 1 1 1 1IT Experian 1 1 1 1 1 1 1 1 1PL BIK 1 1 1 1 1 1 1 1 1 1PL ERIF 1 1 1 1XK CBRK 1 1 1 1 1 1 1 1 1RO BDC S.A. 1 1 1 1 1 1 1 1 1RU UCB 1 1 1 1 1 1 1 1 1 1RS ASB 1 1 1 1 1ES EquifaxES Experian 1 1 1SK CRIFSW CreditsafeSW UC ABCH CRIF 1 1 1 1NL BKR 1 1 1 1UK Callcredit 1 1 1 1 1 1 1 1 1UK Equifax 1,00 1,00 1,00 1,00 1UK Experian 1 1 1 1 1 1 1 1 1

Negative PositiveCredit line on current account (Overdraft)

54

Table 23Depth of data: Internet service provider

defa

ult (

>3 m

onth

)

in a

rrea

rs (1

-3 m

onth

s)

reje

cted

cheq

ue lis

t

num

ber o

f miss

ed p

aym

ents

writ

e-of

fs

Orig

inal

cont

ract

am

ount

Out

stan

ding

am

ount

Paym

ent t

erm

s

inte

rest

rate

Dura

tion

of lo

an

On

time

paym

ent

AT CRIF 1 1AT KSV1870 BE BNBHR HROKCY ArtemisCZ CRIFCZ SOLUS 1 1 1 1 1DK ExperianFI SuomenDE Creditreform 1DE SCHUFA 1 1EL TiresiasHU BISZIS CREDITINFO 1IT CRIFIT ExperianPL BIKPL ERIF 1 1 1 1XK CBRKRO BDC S.A.RU UCBRS ASBES Equifax 1ES Experian 1 1 1SK CRIFSW CreditsafeSW UC ABCH CRIF 1 1NL BKRUK CallcreditUK EquifaxUK Experian

Negative PositiveInternet service provider

55

Table 24Depth of data: Satellite/cable TV

defa

ult (

>3 m

onth

)

in a

rrea

rs (1

-3 m

onth

s)

reje

cted

cheq

ue lis

t

num

ber o

f miss

ed p

aym

ents

writ

e-of

fs

Orig

inal

cont

ract

am

ount

Out

stan

ding

am

ount

Paym

ent t

erm

s

inte

rest

rate

Dura

tion

of lo

an

On

time

paym

ent

AT CRIF 1 1AT KSV1870 BE BNBHR HROKCY ArtemisCZ CRIFCZ SOLUSDK ExperianFI SuomenDE Creditreform 1DE SCHUFAEL TiresiasHU BISZIS CREDITINFO 1IT CRIFIT ExperianPL BIKPL ERIF 1 1 1 1XK CBRKRO BDC S.A.RU UCBRS ASBES EquifaxES Experian 1 1 1SK CRIFSW CreditsafeSW UC ABCH CRIF 1 1NL BKRUK CallcreditUK Equifax 1.00 1.00 1.00 1.00 1 1 1 1 1UK Experian 1 1 1 1 1 1 1 1 1

Negative PositiveSatellite/cable TV

56

Table 25Depth of data: Fixed line Telecoms

defa

ult (

>3 m

onth

)

in a

rrea

rs (1

-3 m

onth

s)

reje

cted

cheq

ue lis

t

num

ber o

f miss

ed p

aym

ents

writ

e-of

fs

Orig

inal

cont

ract

am

ount

Out

stan

ding

am

ount

Paym

ent t

erm

s

inte

rest

rate

Dura

tion

of lo

an

On

time

paym

ent

AT CRIF 1 1AT KSV1870 BE BNBHR HROKCY ArtemisCZ CRIFCZ SOLUS 1 1 1 1 1 1DK ExperianFI SuomenDE Creditreform 1DE SCHUFA 1 1EL TiresiasHU BISZIS CREDITINFO 1IT CRIFIT ExperianPL BIKPL ERIF 1 1 1 1XK CBRKRO BDC S.A.RU UCBRS ASBES Equifax 1ES Experian 1 1 1SK CRIFSW CreditsafeSW UC ABCH CRIF 1 1 1 1NL BKRUK CallcreditUK Equifax 1,00 1,00 1,00 1,00 1 1 1 1 1UK Experian 1 1 1 1 1 1 1 1 1

Negative PositiveFixed line Telecoms

57

Table 26Depth of data: Telecoms - mobile

defa

ult (

>3 m

onth

)

in a

rrea

rs (1

-3 m

onth

s)

reje

cted

cheq

ue lis

t

num

ber o

f miss

ed p

aym

ents

writ

e-of

fs

Orig

inal

cont

ract

am

ount

Out

stan

ding

am

ount

Paym

ent t

erm

s

inte

rest

rate

Dura

tion

of lo

an

On

time

paym

ent

AT CRIF 1 1AT KSV1870 BE BNBHR HROKCY ArtemisCZ CRIFCZ SOLUS 1 1 1 1 1 1DK ExperianFI SuomenDE Creditreform 1DE SCHUFA 1 1EL TiresiasHU BISZIS CREDITINFO 1IT CRIFIT ExperianPL BIKPL ERIF 1 1 1 1XK CBRKRO BDC S.A.RU UCBRS ASBES Equifax 1ES Experian 1 1 1SK CRIFSW CreditsafeSW UC ABCH CRIF 1 1 1 1NL BKR 1 1 1 1UK Callcredit 1 1 1 1 1 1 1UK Equifax 1,00 1,00 1,00 1,00 1 1 1 1 1UK Experian 1 1 1 1 1 1 1 1

Negative PositiveTelecoms - mobile

58

Table 27Depth of data: Payday loans/SMS loans

defa

ult (

>3 m

onth

)

in a

rrea

rs (1

-3 m

onth

s)

reje

cted

cheq

ue lis

t

num

ber o

f miss

ed p

aym

ents

writ

e-of

fs

Orig

inal

cont

ract

am

ount

Out

stan

ding

am

ount

Paym

ent t

erm

s

inte

rest

rate

Dura

tion

of lo

an

On

time

paym

ent

AT CRIFAT KSV1870 BE BNBHR HROKCY ArtemisCZ CRIF 1 1 1 1 1 1 1 1 1CZ SOLUS 1 1 1 1 1 1 1 1 1DK ExperianFI SuomenDE Creditreform 1 1 1 1 1 1 1 1DE SCHUFAEL Tiresias 1 1 1 1 1 1 1HU BISZ 1 1 1 1 1 1IS CREDITINFO 1IT CRIFIT ExperianPL BIK 1 1 1 1 1 1 1 1 1 1PL ERIF 1 1 1 1XK CBRKRO BDC S.A. 1 1 1 1 1 1 1 1 1RU UCB 1 1 1 1 1 1 1 1 1RS ASBES Equifax 1ES Experian 1 1 1 1 1 1 1 1SK CRIF 1 1 1 1 1 1 1 1 1SW CreditsafeSW UC AB 1 1 1 1CH CRIFNL BKRUK Callcredit 1 1 1 1 1 1 1 1 1UK Equifax 1,00 1,00 1,00 1,00 1 1 1 1 1UK Experian 1 1 1 1 1 1 1 1

Negative PositivePayday loans/SMS loans

59

Table 28Depth of data: Home rent

defa

ult (

>3 m

onth

)

in a

rrea

rs (1

-3 m

onth

s)

reje

cted

cheq

ue lis

t

num

ber o

f miss

ed p

aym

ents

writ

e-of

fs

Orig

inal

cont

ract

am

ount

Out

stan

ding

am

ount

Paym

ent t

erm

s

inte

rest

rate

Dura

tion

of lo

an

On

time

paym

ent

AT CRIFAT KSV1870 BE BNBHR HROKCY ArtemisCZ CRIFCZ SOLUSDK ExperianFI SuomenDE Creditreform 1 1 1 1 1DE SCHUFA 1 1EL TiresiasHU BISZIS CREDITINFOIT CRIFIT ExperianPL BIKPL ERIF 1 1 1 1XK CBRKRO BDC S.A.RU UCBRS ASBES EquifaxES Experian 1 1 1SK CRIFSW CreditsafeSW UC ABCH CRIF 1NL BKRUK CallcreditUK EquifaxUK Experian 1 1 1 1 1 1 1 1 1

Negative PositiveHome rent

60

Table 29Depth of data: Leasing

defa

ult (

>3 m

onth

)

in a

rrea

rs (1

-3 m

onth

s)

reje

cted

cheq

ue lis

t

num

ber o

f miss

ed p

aym

ents

writ

e-of

fs

Orig

inal

cont

ract

am

ount

Out

stan

ding

am

ount

Paym

ent t

erm

s

inte

rest

rate

Dura

tion

of lo

an

On

time

paym

ent

AT CRIF 1 1AT KSV1870 1 1 1 1 1BE BNBHR HROK 1 1 1 1 1 1 1 1CY Artemis 1 1 1 1 1 1 1CZ CRIF 1 1 1 1 1 1 1 1 1CZ SOLUS 1 1 1DK ExperianFI SuomenDE Creditreform 1DE SCHUFA 1 1 1 1 1 1EL Tiresias 1 1 1 1 1 1 1HU BISZ 1 1 1 1 1 1IS CREDITINFOIT CRIF 1 1 1 1 1 1 1 1IT ExperianPL BIK 1 1 1 1 1 1 1 1 1 1PL ERIF 1 1 1 1XK CBRK 1 1 1 1 1 1 1 1 1RO BDC S.A. 1 1 1 1 1 1 1 1 1RU UCBRS ASB 1 1 1 1 1ES EquifaxES Experian 1 1 1SK CRIF 1 1 1 1 1 1 1 1 1SW CreditsafeSW UC ABCH CRIF 1NL BKR 1 1 1 1UK CallcreditUK Equifax 1,00 1,00 1,00 1,00 1 1 1 1 1UK Experian 1 1 1 1 1 1 1 1 1

Negative PositiveLeasing

61

Table 30Depth of data: Health insurance

*Equifax UK hold this data where Credit agreements are involved

defa

ult (

>3 m

onth

)

in a

rrea

rs (1

-3 m

onth

s)

reje

cted

cheq

ue lis

t

num

ber o

f miss

ed p

aym

ents

writ

e-of

fs

Orig

inal

cont

ract

am

ount

Out

stan

ding

am

ount

Paym

ent t

erm

s

inte

rest

rate

Dura

tion

of lo

an

On

time

paym

ent

AT CRIFAT KSV1870 BE BNBHR HROKCY ArtemisCZ CRIFCZ SOLUSDK ExperianFI SuomenDE Creditreform 1DE SCHUFAEL TiresiasHU BISZIS CREDITINFOIT CRIFIT ExperianPL BIKPL ERIF 1 1 1XK CBRKRO BDC S.A.RU UCBRS ASBES Equifax 1ES ExperianSK CRIFSW CreditsafeSW UC ABCH CRIFNL BKRUK CallcreditUK Equifax 1,00 1,00 1,00 1,00 1 1 1 1 1UK Experian

Negative PositiveHealth insurance

62

Table 31Depth of data: Other insurances

*Equifax UK hold this data where Credit agreements are involved

defa

ult (

>3 m

onth

)

in a

rrea

rs (1

-3 m

onth

s)

reje

cted

cheq

ue lis

t

num

ber o

f miss

ed p

aym

ents

writ

e-of

fs

Orig

inal

cont

ract

am

ount

Out

stan

ding

am

ount

Paym

ent t

erm

s

inte

rest

rate

Dura

tion

of lo

an

On

time

paym

ent

AT CRIFAT KSV1870 BE BNBHR HROKCY ArtemisCZ CRIFCZ SOLUSDK ExperianFI SuomenDE Creditreform 1DE SCHUFA 1EL TiresiasHU BISZIS CREDITINFOIT CRIFIT ExperianPL BIKPL ERIF 1 1XK CBRK 1 1 1 1 1RO BDC S.A.RU UCBRS ASBES Equifax 1ES Experian 1 1 1SK CRIFSW CreditsafeSW UC ABCH CRIF 1 1NL BKRUK CallcreditUK Equifax 1 1 1 1 1 1 1 1 1UK Experian 1 1 1 1 1 1 1 1 1

Negative PositiveOther insurances

63

Table 32Depth of data: Others

defa

ult (

>3 m

onth

)

in a

rrea

rs (1

-3 m

onth

s)

reje

cted

cheq

ue lis

t

num

ber o

f miss

ed p

aym

ents

writ

e-of

fs

Orig

inal

cont

ract

am

ount

Out

stan

ding

am

ount

Paym

ent t

erm

s

inte

rest

rate

Dura

tion

of lo

an

On

time

paym

ent

AT CRIFAT KSV1870 BE BNBHR HROK 1 1 1 1 1 1 1 1CY ArtemisCZ CRIF 1 1 1 1 1 1CZ SOLUSDK ExperianFI SuomenDE CreditreformDE SCHUFAEL TiresiasHU BISZ 1 1 1 1 1 1IS CREDITINFOIT CRIFIT ExperianPL BIKPL ERIFXK CBRKRO BDC S.A.RU UCBRS ASBES Equifax 1 1 1 1 1 1ES Experian 1 1 1 1SK CRIF 1 1 1 1 1 1 1 1 1SW CreditsafeSW UC ABCH CRIF 1 1NL BKR 1 1 1 1UK CallcreditUK Equifax 1 1 1 1 1UK Experian

Negative PositiveOthers

64

Annex V. Compliance with special standards

Table 33 Do you comply with special standards?

Do you comply with special standards?

AT CRIF N/A AT KSV1870 No BE BNB No HR HROK No CY Artemis Yes ISO 9001:2015, ISO 27001:2013 CZ CRIF No CZ SOLUS Yes ISO 27001 DK Experian Yes ISO 27001 FI Suomen Yes ISO 9001 DE Creditreform No DE SCHUFA N/A EL Tiresias Yes ISO 9001:2015 HU BISZ Yes ISO 9001 and ISO27001 IS CREDITINFO Yes ISO 27001 in process IT CRIF Yes ISO 9001, ISO 27001 IT Experian No PL BIK Yes ISO/IEC 27001:2013 PL ERIF Yes Our database is verified by an independent auditor - KPMG Audit Ltd. LLP XK CBRK No RO BDC S.A. No RU UCB No RS ASB Yes ISO 27001 ES Equifax Yes ISO 27001 ES Experian No SK CRIF No SW Creditsafe No SW UC AB No CH CRIF No NL BKR Yes ISO2 7001 3600N - Privacy Audit proof UK Callcredit Yes ISO UK Equifax Yes ISO 27001 UK Experian Yes

65

Annex VI. Legal and Regulatory Environment

Table 34 What is the legislation/regulation on access to data?

What is the legislation/regulation on access to data?

AT CRIF Insolvency Code/Enforcement Code AT KSV1870 N/A BE BNB Code of Economic law HR HROK N/A CY Artemis The "Directive for the Operation of a System or a Mechanism for the Exchange,

Collection and Provision of data of 2015" of Central Bank of Cyprus (Appendix B and Article 8.2)

CZ CRIF N/A CZ SOLUS N/A DK Experian N/A FI Suomen Consumer Credit Law DE Creditreform The legitimate interest is defined in § 29 (2) BDSG by the legislator and surveilled by

the LDI DE SCHUFA 29 (2) Federal Data Protection EL Tiresias DPA Act and Ministry of Justice Act HU BISZ National Act 2011/112 on information self-determination and freedom of information IS CREDITINFO N/A IT CRIF Legislative Decree 0. 196 of 30 June 2003 IT Experian Legislative Decree 0. 196 of 30 June 2003 - Annex 5 and 7 PL BIK N/A PL ERIF the Act of 9 April 2010 on provision on credit information and exchange of credit data;

unit 12a XK CBRK N/A RO BDC S.A. N/A RU UCB 0 special RS ASB N/A ES Equifax Spanish Organic Law Data Protection ES Experian Art. 7 Regulation implementing Organic Law 15/1999, of 13 December, on the

protection of personal data (RLOPD) SK CRIF N/A SW Creditsafe Credit Information Act SW UC AB The Swedish Credit Information Act CH CRIF Schuldbetreibungs- und Konkursgesetz NL BKR WBP UK Callcredit Freedom to Information in the Public Domain - The Information Commissioners Office

(ICO) UK Equifax Freedom to Information in the Public Domain - The Information Commissioners Office

(ICO)

UK Experian FAC Regulation

66

Table 35 Is there a special legislation/regulation on credit reporting in your country?

Is there a special legislation/regulation on credit reporting in your country?

AT CRIF Yes 152 Trade Resolution AT KSV1870 Yes DSG2000 BE BNB Yes Code of Economic law HR HROK No CY Artemis Yes The "Directive for the Operation of a System or a Mechanism for the Exchange,

Collection and Provision of data of 2015" of Central Bank of Cyprus which results from the "Business of Credit Institutions Laws of 1997 to 2015"

CZ CRIF Yes Banking Act, Consumer Credit Act, Consumer Protection Act CZ SOLUS Yes § 20z of the Consumer Protection Act DK Experian Yes Danish Act on Processing of Personal Data and license issued by the Danish Data

Protection Agency FI Suomen No DE Creditreform Yes LDI DE SCHUFA Yes Section 28a, 28b, 29 (I) + (II) Federal Data Protection Act EL Tiresias Yes DPA Act 26/2004- Terms regarding the lawfulness of personal data processing for

direct commercial or advertising purposes and the ascertainment of credit ability, DPA Act 186/2014, art. 40 of L.3259/2004

HU BISZ YES National Act 2011/122 Central Credit Information System Act IS CREDITINFO Yes IT CRIF Yes Code of conduct and professional practice applying to information systems

managed by private entities with regard to consumer credit, reliability, and timeliness of payments (Published in the Official Journal No. 300 dated 23 December 2004 and subsequently amended per the Notice published in the Official Journal No. 56 dated 9 March 2005)

IT Experian Yes Legislative Decree No. 196 of 30 June 2003 - Annex 5 PL BIK No PL ERIF Yes The Act of 9 April 2010 on provision of credit information and exchange of credit

data - the whole act is relevant XK CBRK Yes Central Bank, Data Protection Agency RO BDC S.A. Yes Data Protection Authority Decision No. 105/2007 on personal data processing by

credit bureaus RU UCB Yes Federal law "About Credit Histories" 218-FZ dated 30 December 2004 RS ASB No ES Equifax Yes ARTICLE 29 LOPD ARTICLE 14 NEW LOPD ES Experian Yes Local Data Protection law (LOPD) and its regulation (RLOPD) SK CRIF Yes Act 129/2010 on Consumer Credits, art. 7 SW Creditsafe Yes Credit Information Act (197:1173) SW UC AB Yes The Swedish Credit Information Act CH CRIF Yes Data protection law, consumer credit law NL BKR No UK Callcredit Yes Credit reference agencies must be licensed by the Financial Conduct Authority,

Data Protection Act of 1998 UK Equifax Yes Credit reference agencies must be licensed by the Financial Conduct Authority,

Data Protection Act of 1998 UK Experian Yes Credit reference agencies must be licensed by the Financial Conduct Authority,

Data Protection Act of 1998

67

Table 36 Is your organisation subject to sectorial supervision?

Is your organisation subject to sectorial supervision?

AT CRIF No AT KSV1870 Yes Austrian Data protection Authority BE BNB Yes Ministry of Economic Affairs HR HROK No CY Artemis Yes The Central Bank of Cyprus CZ CRIF No CZ SOLUS No DK Experian Yes Danish Data Protection Agency FI Suomen Yes Data Protection Ombudsman’s Office DE Creditreform Yes LDI - Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-

Westfalen; LDI - State Representative for Data Protection and Freedom of Information North Rhine-Westphalia

DE SCHUFA Yes The German Data Protection Law ("BDSG") and the data protection laws of the German 'Länder' are applicable for handling of data. With reference to these 'special' laws credit bureaus are supervised by the local data protection authority that is responsible for that 'Land' within Germany.

EL Tiresias Yes Data Protection Authority (DPA) HU BISZ Yes Central Bank IS CREDITINFO Yes Icelandic Data Protection Authority IT CRIF Yes Data Protection Authority (Autorità garante per la protezione dei dati personali) IT Experian Yes Garante per la protezione dei dati personali (aka Garante) PL BIK No PL ERIF Yes Ministry of Economic Development XK CBRK Yes Central Bank, Data Protection Agency RO BDC S.A. Yes Data Protection Authority RU UCB Yes Central bank of the Russian Federation RS ASB Yes Central Bank, Data Protection Commissioner ES Equifax No ES Experian No SK CRIF No SW Creditsafe Yes Data Inspection Board SW UC AB Yes Data Protection Authorities CH CRIF Yes EDOB Eidgengossischer Datenschutz und Offenttichkeits-Beauttragter NL BKR No UK Callcredit Yes Credit reference agencies are licensed by the Financial Conduct Authority UK Equifax No UK Experian Yes Financial Conduct Authority

68

Table 37 Regulation that require data sharing

Is there a regulation requiring to share

credit data? Is there a regulation requiring to share

non-credit data? AT CRIF N/A N/A AT KSV1870 Yes CCD No BE BNB Yes Code of Economic Law Yes Royal Decree of 22 April 1999 on

collective debt settlements HR HROK No No CY Artemis Yes Directive for the Operation of a

System or a Mechanism for the Exchange, Collection and Provision of data of 2015 of Central Bank of Cyprus

No

CZ CRIF No No CZ SOLUS No No DK Experian Yes Danish Act on Processing of

Personal Data and credit bureau license issued by the Danish Data Protection Agency

Yes Danish act on Processing of Personal Data

FI Suomen No No DE Creditreform Yes BDSG (§§ 28, 28a and 29ff) N/A DE SCHUFA No No EL Tiresias Yes Art. 40 of L.3259/2004 as amended No HU BISZ Yes Nationa Act 2011/122 (Central

Credit Information Act) Yes Family insolvency Service

regulated by National Act 2011/122 (Central Credit Information Act)

IS CREDITINFO Yes National data protection law nr. 77/2000 and regulations based on the laws

Yes National data protection law nr. 77/2000 and regulations based on the laws

IT CRIF Yes Annex A.5 Code of conduct and professional practice applying to information systems Article 1.1.e - Definitions

No

IT Experian Yes Annex A.5 Code of conduct and professional practice applying to information systems Article 1.1.e - Definitions

No Explicitly forseen by Legge 04/08/2017 n. 124 - art.1 comma 85

PL BIK Yes The Banking Law, The Consumer Credit Law, Data Protection Law

No

PL ERIF No No XK CBRK Yes Yes RO BDC S.A. No No RU UCB Yes Federal law About Credit histories

218-FZ, article 5 No

RS ASB Yes Law on Banks, Law on consumer protection, internal regulation

No

ES Equifax No No ES Experian No No

69

SK CRIF Yes Act on Consumer Credits No SW Creditsafe Yes The Swedish Credit Information Act Yes The Swedish Credit Information

Act SW UC AB Yes The Swedish Credit Information Act Yes The Swedish Credit Information

Act CH CRIF Yes Data protection law No NL BKR Yes Act on Financial Services (Wft 4:32) No UK Callcredit No No UK Equifax No No UK Experian No

No

70

Table 38 Regulations that promote data sharing

Are there regulations promoting the sharing of data?

AT CRIF Yes 7 Consumer Credit Act AT KSV1870 Yes Basel 2 Guidelines BE BNB No HR HROK Yes National bank guidelines CY Artemis Yes The Laws of Credit Agreements for Consumers CZ CRIF Yes Consumer credit directive No. 257/2016 CZ SOLUS Yes The Consumer Lending Act requires verifying the credit history of the client but

does not specify it has to be done through a database DK Experian Yes The Danish Consumer Ombudsman, The DK legislation incorporating the EU

directive on consumer credits and the Financial Authorities recommend the use of third party data (bureau data) in order to ensure proper credit assessments

FI Suomen N/A DE Creditreform Yes German Data Protection Law (BDSG) DE SCHUFA Yes KYC, AML, Directive on credit agreements for consumers relating to residential

immovable property EL Tiresias Yes Anti-Money Laundering Regulation, Banking Supervision Regulation HU BISZ No IS CREDITINFO Yes Creditworthiness assessment must be made before consumer lending (loan to a

consumer/individual) IT CRIF Yes Consumer Credit Directive, Mortgage Credit Directive, FSB’s principles for sound

residential mortgage underwriting practices, EBA's Guidelines on creditworthiness assessment

IT Experian No PL BIK Yes Recommendation of Financial Supervisory Authority PL ERIF No XK CBRK Yes RO BDC S.A. Yes Central bank Regulation No. 17/2012 on credit terms RU UCB Yes The banks’ bad debt provisions depends on information obtained. More

information - less amount. RS ASB N/A ES Equifax Yes Law of Consumer Credit Contracts - Sustainable Economy Law ES Experian No SK CRIF Yes Act on Consumer Credits SW Creditsafe Yes Consumer Credit Act SW UC AB Yes The Swedish Consumer Credit Act CH CRIF No NL BKR Yes Prohibition of over crediting by consumer credit providers (including mortgages).

See Wft (Dutch Act on Financial Services) UK Callcredit Yes FCA (Financial Conduct Authority) Guidelines UK Equifax Yes FCA UK Experian Yes FCA Handbook Regulation

71

Table 39 Planned legislation/regulation, which may affect the credit reporting industry

Are you aware of any national legislation/regulation planned in your country, which may affect the credit reporting industry?

AT CRIF N/A AT KSV1870 No BE BNB Yes Implementation of GDPR HR HROK No CY Artemis No CZ CRIF No CZ SOLUS No DK Experian Yes DK implementation of GDPR resulting in new Danish act and regulatory

framework in general as well as new license of the bureau FI Suomen No DE Creditreform No DE SCHUFA Yes Adaptation of the former Federal Data Protection Act to the new GDPR is

already secluded / in place for May 2018. In addition, there are unclear plans to additionally regulate the use of algorithms.

EL Tiresias Yes Implementation of GDPR HU BISZ Yes Implementation of GDPR in the national law IS CREDITINFO No IT CRIF Yes Review of the Code of conduct and professional practice applying to information

systems managed by private entities with regard to consumer credit, reliability, and timeliness of payments

IT Experian Yes Legge 04/08/2017 n.124 PL BIK Yes Implementation of Regulation on Data Protection (May 2018), The new Data

Protection Law, changes in the Banking Law PL ERIF Yes Amendment of 13 November 2017 to the Act of 9 April 2010 (mentioned above) XK CBRK No RO BDC S.A. Yes Implementation of GDPR RU UCB Yes There are major changes of the credit bureau industry planned. We are in

negotiations with the Central bank on design of the changes RS ASB N/A ES Equifax Yes New Spanish organic law data protection ES Experian Yes The new Local data protection law adapting and including GDPR requirements. SK CRIF N/A SW Creditsafe Yes GDPR SW UC AB No CH CRIF Yes New data protection act NL BKR No UK Callcredit Yes GDPR which will be incorporated within UK law post-Brexit UK Equifax N/A UK Experian Yes Data Protection Bill

72

Table 40 Regulation that restricts data sharing

Is there any other law or regulation that restricts data sharing?

AT CRIF Yes AT KSV1870 N/A BE BNB Yes Code of Economic law and Royal Decree of 23 March 2017 HR HROK No CY Artemis Yes Directive for the Operation of a System or a Mechanism for the Exchange,

Collection and Provision of data of 2015 of Central Bank of Cyprus CZ CRIF No CZ SOLUS No DK Experian No FI Suomen Yes Credit Information Act does not allow creditors to share data DE Creditreform No for German lawyers Section 43a (2) of the Federal Lawyers' Code, specified in

more detail in Section 2 BORA and the medical duty of secrecy (also: medical confidentiality or doctor's secret) ends according to § 203 Abs. 4 StGB

DE SCHUFA No EL Tiresias Yes Banking privacy law, consumer protection law, taxation law HU BISZ Yes National Act 2013/237 Credit Institutions and Financial Enterprises Act;

National Act 2011/122 Central Credit Information System Art IS CREDITINFO No IT CRIF No IT Experian No PL BIK Yes The Banking Law - limitation on exchanging of banking secrecy information PL ERIF Yes Act of 9 April 2010, Banking Law XK CBRK Yes Law on the protection of personal data (Law 0.03/L-172; chapter III Rights of

the data subject RO BDC S.A. No RU UCB No RS ASB No ES Equifax No ES Experian No SK CRIF N/A SW Creditsafe Yes Credit Information Act. Regulates the Swedish credit information industry SW UC AB No CH CRIF NA NL BKR No UK Callcredit No UK Equifax No UK Experian No

73

Table 41 Access to public/court data

Is access to public/court data permitted by regulation? If yes, what is the name of regulation?

CY Artemis Yes Directive for the Operation of a System or a Mechanism for the Exchange, Collection and Provision of data of 2015 of Central Bank of Cyprus (Appendix B and Article 8.2)

CZ CRIF Yes DK Experian Yes DE Creditreform Yes § 29 (2) BDSG by the legislator and surveilled by the LDI DE SCHUFA Yes Insolvency Statute EL Tiresias Yes DPA Act and Ministry of Justice Act IS CREDITINFO Yes IT CRIF Yes Legislative Decree No. 196 of 30 June 2003 IT Experian Yes Legislative Decree No. 196 of 30 June 2003 - Annex 5 and 7 PL ERIF Yes Act of 9 April 2010 on provision on credit information and exchange of credit

data; unit 12a RU UCB Yes No special ES Equifax Yes Spanish Organic Law Data Protection ES Experian Yes Art. 7 Regulation implementing Organic Law 15/1999, of 13 December, on the

protection of personal data (RLOPD) SK CRIF Yes SW Creditsafe Yes Credit Information Act SW UC AB Yes The Swedish Credit Information Act NL BKR Yes UK Callcredit Yes Freedom to Information in the Public Domain - The Information Commissioners

Office (ICO)

UK Equifax Yes Freedom to Information in the Public Domain - The Information Commissioners Office (ICO)

UK Experian Yes FAC Regulation Is access to public/court data required by regulation?

If yes, what is the name of regulation? AT CRIF Yes Insolvency Code/Enforcement Code BE BNB Yes Royal Decree of 22 April 1999 on collective debt settlements CY Artemis Yes Directive for the Operation of a System or a Mechanism for the Exchange,

Collection and Provision of data of 2015 of Central Bank of Cyprus (Appendix B and Article 8.2)

FI Suomen Yes Consumer Credit Law UK Callcredit Yes Freedom to Information in the Public Domain - The Information Commissioners

Office (ICO) UK Equifax Yes FCA Guidelines UK Experian Yes FAC Regulation

74

Annex VII. Cross-border data flow

Table 42 Does your CRA share data with CRAs in other countries?

Does your CRA share data with CRAs in other countries?

If yes, please list the relevant countries and indicate how many requests are made every year per country. If no, what is the reason?

What is the underlying legal basis for sharing data with bureaus in

other countries? AT CRIF No AT KSV1870 Yes <5.000 CBDE CONTRACTS BE BNB Yes Netherlands, Germany; <10.000 Private agreement HR HROK No CY Artemis No CZ CRIF No CZ SOLUS No DK Experian No FI Suomen No DE Creditreform Yes Germany, Switzerland and Austria BDSG - Bundesdatenschutzgesetz

(German Data Protection Law) DE SCHUFA Yes Belgium, Greece, Ireland, Italy, Lithuania,

Netherlands, Austria, Poland, Sweden, Switzerland, Spain

§ 4b Federal Data Protection Act; private agreement, based on ACCIS' template

EL Tiresias Yes Germany; 10 Bilateral Agreement based on European and National Legislation

HU BISZ No IS CREDITINFO Yes EU countries IT CRIF Yes Austria 0, Germany 147, Netherlands

1.267 Both legislation and private agreements

IT Experian No PL BIK Yes <10 Private agreement PL ERIF No XK CBRK No RO BDC S.A. No RU UCB No RS ASB No ES Equifax No ES Experian No SK CRIF No SW Creditsafe Yes Almost all countries in the world Private agreement SW UC AB Yes Norway 189.000, Finland 139.000,

Denmark 49.000 and Germany 0 Private agreement

CH CRIF No NL BKR Yes Germany 4.700, Belgium 4.500, Italy

1.200, Austria 200, Dutch Antilles 20 Private agreement

UK Callcredit No UK Equifax Yes PSD2 Open banking UK Experian Yes

75

Table 43 Does your CRA have access to data from CRAs in other countries?

Does your CRA have access to data from CRAs in other countries?

If yes, please list the relevant countries and indicate how many requests are made every year per country. If no, what is the reason?

What is the underlying legal basis for sharing data with bureaus in

other countries?

AT CRIF No AT KSV1870 N/A BE BNB Yes Netherlands, Germany; <10.000 Private agreement HR HROK No CY Artemis No CZ CRIF No CZ SOLUS No DK Experian Yes Contract FI Suomen No DE Creditreform Yes Germany, Switzerland and Austria BDSG - Bundesdatenschutzgesetz

(German Data Protection Law) DE SCHUFA Yes Belgium, Greece, Ireland, Italy, Lithuania,

Netherlands, Austria, Poland, Sweden, Switzerland, Slovenia, Spain

Private agreement, based on ACCIS' template

EL Tiresias Yes Germany 10 Bilateral Agreement based on European and Nat. Legislation

HU BISZ No IS CREDITINFO Yes EU countries IT CRIF Yes Austria 0, Germany 147, Netherlands

1.267 Both legislation and private agreements

IT Experian No PL BIK No PL ERIF No XK CBRK No RO BDC S.A. No RU UCB No RS ASB No ES Equifax No ES Experian No SK CRIF No SW Creditsafe Yes Almost all countries in the world Private agreement SW UC AB Yes Norway 189.000, Finland 139.000,

Denmark 49.000 and Germany 0 Private agreement

CH CRIF Yes Austria, Germany, Czech Republic, Slovakia; CA 500.000

Private agreement

NL BKR Yes UK Callcredit No UK Equifax No UK Experian N/A

76

Table 44 Does your CRA share data with financial institutions in other countries (direct access)?

Does your CRA share data with financial institutions in other countries (direct access)?

AT CRIF No AT KSV1870 N/A BE BNB No HR HROK No CY Artemis No CZ CRIF No CZ SOLUS No DK Experian Access FI Suomen N/A DE Creditreform Share DE SCHUFA Access and Share EL Tiresias No HU BISZ No IS CREDITINFO No IT CRIF Access and Share IT Experian No PL BIK No PL ERIF Access and Share XK CBRK No RO BDC S.A. No RU UCB No RS ASB No ES Equifax No ES Experian No SK CRIF No SW Creditsafe No SW UC AB No CH CRIF Access NL BKR No UK Callcredit No UK Equifax No UK Experian Share

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