Client Update – Privacy In Advanced Means of Payment
28 April 2021
Dear client and friends,
We would like to draw your attention that on April 22, 2021, the Israeli Protection of Privacy Authority
(the “PPA“) has published its final form policy document regarding privacy in advanced means of payment for the transfer of funds and for payments in businesses (the “Policy“). The Policy includes recommendations for managing the use of advanced means of payments in term of privacy, consent and data security. It should be noted that the Policy does not apply to or deal with websites and applications managed by banks through which customers perform various financial transactions online.
Nowadays, the main advanced means of payment active in Israel operate in two main configurations:
(1) means of payment for the transfer of funds – transfer of funds between individuals (P2P) or collection of payments within a group; and (2) Payment in a business – payments are transferred directly to the business via smartphones and/or other smart device using NFC technology.
In general, the PPA notes that the use of advanced means of payment has many advantages, however, while using these means, significant questions of privacy and data security arise, in light of the fact that, according to a review conducted by the PPA, these advanced means collect sensitive data about users which allows the data collector to analyze the behavior (both general and economic) of the users in a way that may attest to the personalities of the users, their preferences and lifestyle, while sometimes doing so for commercial purposes and, in some occasions, passing such data to third-parties.
In light of the above, the PPA notes that it must be ensured that the use of advanced means of payment is done in a way that will protect the privacy of the users, and which allows the users to control such data.
To this end, the PPA draws up a series of recommendations, which, in the PPA’s opinion, express the best way to implement the provisions of the Protection of Privacy Law, 1981 (the “Law“), and to give due importance to the issue of the privacy of the users of the advanced means of payment.
The following are the main recommendations of the PPA:
- Consent to use other technologies – any material change in the type or identity of the technologies used in the advanced means of payment, will be presented to users in order to obtain a renewed active consent on their behalf, including detailing the possible meanings and implications of the said changes on their privacy.
To read the policy in its full form (in Hebrew) >> click here
Please do not hesitate to contact us if you have any questions or require any clarification regarding the above.
Herzog Fox and Neeman