Financial Services
Financial institutions face an unusually dense intersection of regulatory requirements. GDPR, FADP, MiFID II, PSD2, DORA, and FINMA create overlapping obligations that demand specialist navigation — not a generic compliance checklist.
The Regulatory Intersection Problem
Financial services organisations face a compliance environment where multiple regulatory frameworks impose conflicting obligations on the same data. MiFID II requires multi-year transaction data retention; GDPR mandates data minimisation and purpose limitation. PSD2 creates data sharing requirements; GDPR requires lawful basis and processor agreements for every transfer.
Most compliance programmes address these frameworks in siloes — a legal team handles GDPR, a technology team handles DORA, a compliance team handles MiFID. The result is a patchwork that satisfies none of them adequately. Qala's approach maps all obligations to the underlying data flows first, then resolves conflicts at the source rather than through sequential bolt-on reviews.
Core areas we address
- Data residency and transfer constraints — FADP and GDPR both restrict international data transfers; for CH-domiciled institutions serving EU clients, this requires dual-regime transfer mapping
- MiFID II data lineage — transaction data documentation requirements aligned with GDPR purpose limitation and minimisation principles
- PSD2 data sharing frameworks — Open Banking data access with documented lawful basis, consent architecture, and processor agreements
- DORA operational resilience — data pipeline health monitoring and ICT risk documentation that aligns with your GDPR accountability obligations
- FINMA overlap for Swiss institutions — supervisory authority expectations for data governance, outsourcing, and incident reporting under Swiss law
- Automated decision-making under Art. 22 — credit scoring, fraud detection, and algorithmic risk models require specific GDPR transparency and challenge provisions
Regulatory Framework Overlap — FS
GDPR / FADP
Lawful basis, data minimisation, ROPA, DPIA, DSR obligations
MiFID II / EMIR
Transaction reporting, 5–7yr retention, data lineage audit trail
DORA
ICT risk management, operational resilience, incident reporting
FINMA (CH only)
Outsourcing guidance, data governance, supervisory reporting
What Makes FS Compliance Different
Three characteristics that distinguish financial services data compliance from other industries — and why a generic GDPR consultant is insufficient.
Retention conflicts are structurally unavoidable
MiFID II requires 5–7 year transaction records. GDPR requires you to delete data when the original purpose expires. These cannot both be satisfied without explicit legal analysis of each data category. Most FS firms handle this ad hoc; Qala builds a documented retention matrix that satisfies both.
Automated decisions require documented justification
Credit scoring, transaction fraud detection, and algorithmic underwriting all trigger Art. 22 GDPR provisions. If your models process personal data to make decisions with legal or significant effects, you need documented safeguards, a logic explanation, and a challenge mechanism. Qala maps your models to these requirements.
Swiss institutions face a dual regime
A Zurich-based bank serving EU clients must satisfy both FADP (nDSG) and GDPR simultaneously. FADP has some requirements that exceed GDPR — privacy notices, impact assessments, and certain transfer restrictions apply differently. Qala's Zurich base means we work in this dual regime daily, not occasionally.
Financial services compliance that spans the full regulatory stack
We map your regulatory obligations — GDPR, FADP, MiFID II, DORA — to your actual data landscape, then build a compliance posture that holds up under supervisory scrutiny.