Navigating 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.