We capture how personal data actually moves through your services, and which systems and suppliers are involved, to identify what needs to be addressed first.
Navigating GDPR in fintech companies
Our data protection lawyers help fintech companies apply GDPR and regulatory requirements
Navigating GDPR in fintech companies
At Morling Consulting, we regularly support fintech companies in navigating GDPR. Our privacy counsels and experts in data protection and financial regulation offer strategic advice on complex questions—such as how GDPR aligns with anti-money laundering requirements.
GDPR (the General Data Protection Regulation) has a significant impact on the fintech sector, where processing of personal data is central to many companies. GDPR, in force since 2018, is a general legislation aimed at strengthening the protection of personal data for all individuals within the EU and EEA. For fintech companies, which often have innovative business models, this means a range of challenges in ensuring compliance, as the requirements are generally designed and often difficult to apply, especially in financial businesses.
A fundamental principle of the GDPR, highly relevant for fintech companies, is the requirement of privacy by design and by default, meaning that data protection should be considered at the earliest stages of system and process development, and that only the data necessary for a specific purpose should be processed. Privacy by design means integrating data protection into systems and processes from the very start. Privacy by default ensures that high protection levels apply automatically—without requiring action from the user.
Approach for GDPR in fintech
We translate GDPR requirements into your context and weigh them against your business model and regulatory obligations, so risks and dependencies are clear for decision-making.
You receive a workable plan with clear ownership points and a sensible order of priorities across technology, processes, and governance, so measures have impact without disrupting the core business.
We prepare and update the necessary documentation and support implementation in ways of working and systems, so you can demonstrate compliance in customer queries and during supervisory reviews.
We establish routines for recurring checks, incident handling, and data subject request management, so data protection holds as the business scales and changes.
Privacy in fast growth
In fintech, high regulatory demands, complex supply chains and rapid product changes come together. Secure the fundamentals with contracts, records and incident readiness so you can scale without losing control. Click through to choose the right focus areas for your environment.
Processing personal data in fintech companies
All processing of personal data must be carried out according to the seven principles listed in GDPR. These are:
- Personal data shall be processed lawfully, fairly, and transparently in relation to the data subject.
- Personal data shall be collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
- Personal data shall be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
- Personal data shall be accurate and kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
- Personal data shall not be stored for a longer period than is necessary for the purposes for which the personal data are processed.
- Personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.
- The controller shall be responsible for and able to demonstrate compliance with these principles.
For fintech companies, which often collect and processes large amounts of data to offer personalized and automated financial services, these principles are particularly relevant. Companies must ensure that the processing of personal data is in accordance with these principles and other requirements of GDPR. This requires clear communication with users and robust mechanisms to ensure compliance.
Streamlining Operations
The key to user’s trust in fintech services
The GDPR imposes high requirements on data security. Fintech companies often handle financial information, making them attractive targets for cyberattacks. GDPR mandates that companies implement both technical and organizational safeguards to protect personal data from unauthorized access, loss, or damage. This can include encryption or pseudonymization, regular security audits, and staff training in data protection issues.
GDPR grants individuals the right to access their personal data, correct inaccurate data, and request the erasure of their data, also known as the “right to be forgotten”. These rights are often challenging in operations that handle large amounts personal data and require the correct level of verification of the individual’s identity before disclosing information. Fintech companies need to have effective processes in place to handle such requests and ensure that these rights are respected.
GDPR also has strict rules on data transfers outside the EU/EEA, so-called third-country transfers. Fintech companies operating internationally must ensure that personal data transferred to third countries have an adequate level of protection, which may require the use of standard contractual clauses or other safeguards.
Build your fintech operations for the future
GDPR has a significant impact on the fintech sector, requiring companies to carefully consider and adapt their data protection routines. By complying with GDPR, fintech companies can not only avoid potential sanctions but also build trust with their customers by demonstrating that they take their privacy seriously. This trust is crucial for long-term success in a competitive and rapidly changing market.
Get in touch with Morling Consulting if your business needs hands-on expertise in personal data processing within the financial regulatory landscape.
Frequently asked questions about GDPR in fintech companies
The GDPR imposes extensive requirements on how personal data is handled, which has a particular impact on fintech companies, since their services are often data-driven. Fintech companies must ensure that its data processing aligns with the principles of the GDPR and that both technical and organizational measures are put in place – at a level that corresponds to the risks involved in their data processing activities.
Key challenges include interpreting and applying general data protection rules in a complex financial environment, managing large volumes of data, meeting individuals’ rights, and ensuring lawful data transfers to countries outside the EU/EEA. Since the GDPR is a principles-based regulation, the innovative and fast-moving nature of the fintech sector can make it difficult to identify practical solutions that comply with the law.
To comply with GDPR security obligations, fintech companies should consider measures such as:
- Conducting regular risk assessments.
- Using encryption and/or pseudonymization of personal data.
- Ensuring systems and processes protect against unauthorized access, loss, or damage.
- Training staff on data protection.
- Establishing procedures for handling data breaches.
Morling Consulting supports the implementation of technical and organizational security measures by assessing the risks involved in the company’s data processing.
The GDPR doesn’t prohibit automated decision-making – but it sets clear conditions. When a decision is made automatically (for example, approving or denying a loan), the individual has the right to understand how that decision was made and to object if something seems incorrect. In some cases, the person also has the right to have the decision reviewed by a human.
For fintech companies using automation responsibly, it’s important to consider how the technology may impact individuals’ rights. Morling Consulting helps companies create clear routines and solutions so that innovation and privacy go hand in hand.
Data transfers to so-called third countries require specific safeguards, such as standard contractual clauses. Fintech companies using cloud services or operating internationally need to carefully review their data transfer arrangements and ensure they comply with the GDPR. Morling Consulting provides guidance on managing international data transfers.
Companies must implement processes to handle rights such as access, rectification, erasure, and data portability. This also includes verifying the identity of the individual making the request. These processes should not be more burdensome than necessary, and must strike the right balance between safeguarding data and respecting individual rights. Morling Consulting helps develop effective and legally compliant routines.
We offer comprehensive support to help ensure GDPR compliance, including:
- Ongoing legal advice on data protection and financial regulation.
- Review and development of internal policies and governance documents.
- Conducting risk analyses and data protection impact assessments (DPIAs).
- Training for management and staff.
- Strategic guidance in developing automated decision-making systems.
- Assistance with data breach handling and communication with supervisory authorities.
Strong data protection is not just a legal obligation – it’s also a competitive advantage. Handling personal data transparently and securely builds customer trust and reduces the risk of sanctions from supervisory authorities such as the Integritetsskyddsmyndigheten and the Swedish Financial Supervisory Authority.
By embedding data protection from day one through the principles of privacy by design and by default. This means:
- Integrating data protection into every stage of product and system development.
- Collecting and processing only the personal data strictly necessary for each purpose.
- Implementing safeguards such as encryption, access controls, and activity logging from the start.
Morling Consulting offers legal support throughout the development process to align data processing with both GDPR and relevant financial regulations. Getting this right early on helps prevent costly adjustments later and builds trust from the outset.
A Data Protection Impact Assessment (DPIA) is required when personal data processing is likely to pose a high risk to individuals’ rights and freedoms—a common scenario in fintech, where advanced analytics and automation are often used. DPIAs are particularly relevant in cases such as:
- Automated decision-making or profiling.
- Systematic tracking of user behavior.
- Large-scale processing of sensitive data.
Morling Consulting helps determine when a DPIA is needed and ensures it is conducted properly. We also help develop concrete risk mitigation strategies—whether that means adjusting decision logic, adding safeguards, or improving transparency toward users.
ePrivacy, which complements the GDPR, governs how companies can use digital communications and online tracking technologies. This is especially relevant for fintech businesses that rely on user data for marketing or analytics. Key aspects include:
- Requirements for obtaining valid consent before using cookies and similar tools.
- Rules on electronic direct marketing, such as email or SMS outreach.
Morling Consulting closely monitors the evolving ePrivacy framework and provides strategic advice on how fintech companies can act proactively. In a sector driven by digital engagement, staying ahead of these rules is essential to avoid disruption and maintain user trust.
We provide hands-on, business-oriented guidance tailored to your company’s operational and regulatory landscape. Our support often includes:
- Analyzing how GDPR and anti-money laundering (AML) obligations intersect in onboarding flows.
- Reviewing how new fintech tools handle personal data in line with privacy by design.
- Designing internal procedures for handling access, deletion, and other user rights.
- Advising on structuring automated decision-making to meet legal requirements and ensure accountability.
We don’t just interpret the rules—we help build practical, defensible systems that stand up to real-world scrutiny. Our aim is to make data protection a strategic asset, not a compliance burden.
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