First Data gains European approval for BCRs

LONDON, November 14, 2011

SNR Denton has successfully helped First Data Corporation, a global leader in electronic commerce and payment processing, obtain approval from European Data Protection regulators for its Binding Corporate Rules for data privacy (BCRs).

Today, the Information Commissioner’s Office granted authorisation of First Data's BCRs, making it the eleventh company to obtain such authorization. First Data is one of only a handful of other companies worldwide who have completed this rigorous process to establish of the highest standards global data privacy practices. Its BCRs have been approved by the data protection authorities in 18 European Union member states.

The authorisation marks the culmination of a four-year project by First Data which was led on First Data's side by John Atkins, First Data’s Chief Privacy Officer, and Tanya Madison Cunningham, Senior Counsel, Technology, Regulatory Compliance and Privacy.

SNR Denton's team was lead by Head of Technology Media and Telecoms sector, Scott Singer, assisted by Associates Nicola Tutton and Tristan Jonckheer, all of whom work in SNR Denton's dedicated UK Data Privacy Group, which has 4 partners and 12 lawyers in total, making it one of the largest in the UK.

Scott Singer commented: "Data Privacy is at the heart of First Data's business, being a company which processes literally tens of billions of transactions every year. First Data's determination to complete this process has come out of not just a desire to streamline its business, but more importantly, a wish to demonstrate its commitment to maintaining the highest standards of data privacy in everything it does."

John Atkins, First Data’s Chief Privacy Officer, said: “First Data appreciates the superior guidance we received from SNR Denton during this process. Only a handful of companies have achieved BCR approval due to the rigorous nature of the process, and the advice and partnership provided by the SNR Denton team were invaluable.”

David Smith, Deputy Information Commissioner, said: “First Data should be commended for its commitment to the concept of binding corporate rules and for the respect for the privacy of individuals that this demonstrates. The ICO welcomes approaches from multi-national organisations that need to share personal information within their own group, but outside Europe and who want to use binding corporate rules to enable that."

BCRs are a company-wide privacy policy to guarantee that a company's practices are consistent with European data protection law. They are considered the platinum standard for compliance with the European Data Protection Directive. First Data's BCRs will allow First Data to transfer personal data from the European Economic Area to its affiliates elsewhere in the world – something which is prohibited under the European Data Protection Directive unless adequate safeguards are in place. Following approval of the binding corporate rules by the European data protection regulators, First Data will now go through the formal process of approaching each of them for local authorization (the ICO's having been the first such authorisation to be granted).

About SNR Denton

SNR Denton is a client-focused international legal practice delivering quality and value. We serve clients in key business and financial centers from more than 60 locations in 43 countries, through offices, associate firms and special alliances across the US, the UK, Europe, the Middle East, Russia and the CIS, Asia Pacific and Africa, making us a top 25 legal services provider by lawyers and professionals worldwide. Joining the complementary top tier practices of its founding firms -- Sonnenschein Nath & Rosenthal LLP and Denton Wilde Sapte LLP -- SNR Denton offers business, government and institutional clients premier service and a disciplined focus to meet evolving needs in eight key industry sectors: Energy, Transport and Infrastructure; Financial Institutions and Funds; Government; Health and Life Sciences; Insurance; Manufacturing; Real Estate, Retail and Hotels; and Technology, Media and Telecommunications. Please see snrdenton.com for more information and Legal Notices.

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