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canadian goose jacket NAFCU Compliance Team has seen an uptick in questions about the scope of the European Union General Data Protection Regulation (GDPR). Apparently some vendors are raising the red flag for their clients. NAFCU recently hosted a webcast (for purchase) on the GDPR which credit unions may find helpful. We also blogged about the GDPR in May of last year, and that might be worth revisiting: Privacy Laws from Across the Pond: Scoping Out the GDPR. canadian goose jacket

canada goose black friday sale The GDPR scope is drawn very broadly. It does not require the credit union to have a location canada goose uk outlet in the EU or for the website user to uk canada goose outlet be an EU citizen or resident for the rule to apply. Here is a section from that prior blog post:The Directive applied mostly to organizations that had an establishment or Canada Goose Online “means of processing” physically located canada goose outlet within the EU. The GDPR, however, expands the application of EU privacy law to organizations not located in the EU, canada goose uk black friday but canada goose clearance doing certain business in the EU. canada goose black friday sale

Canada Goose online For entities that do canada goose not have an establishment in the EU, the GDPR applies to any organization that processes the personal data of natural persons in the EU under two circumstances: 1) when offering them goods or services, even if it canada goose store not in return for payment, or 2) in monitoring their behavior which takes place within the EU. See, EU Regulation 2016/679, Ch. 1, Art. 3(2).” Canada http://www.canadagoosesalesus.com Goose online

canada goose store The full post contains more detail, including the definitions that are necessary to really understand this scope. However, even cheap Canada Goose if the credit union falls within the scope, there is still canada goose coats a question as to whether and when compliance with the rule may be appropriate for individual credit unions. It is not clear how the European Union would enforce the law against organizations without a presence in the EU. Neither the CFPB nor NCUA have indicated an appetite to examine for it. Credit unions seeking a realistic assessment of the risk that GDPR noncompliance would pose to the credit union should speak with an attorney experienced in international law. A proper assessment of this risk should help the credit union assess whether GDPR compliance is appropriate and necessary at this time. canada goose store

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