The law of July 1, 2010, reforming the rules relating to consumer credits considers the creation of the National Register of Credits to Consumers (Registre National des Crédits aux Particuliers). This register, which will be managed by the Banque de France, would be the very first national database to centralize information relating to consumer credits. Until now, in France, only a national file of payment incidents in relation to consumer credits held by the Banque de France has been available (FICP). A committee is in charge of analyzing the conditions under which personal data will be processed in this new register.
The CNIL is part of this committee and indicated that it will make sure that the following key principles will be taken into account:
- a clear definition of the purpose of the register in order to strictly restrict access to the register and prevent access to providers (e.g; energy, telecom, landlords…)
- a restricted data scope limited to credits as opposed to other debts (such as rentals, taxes). A question mark remains on revolving credits
- a definition of a maximum data retention period
- the need of prevention of risks of identity mistakes between homonyms, which require full name collection, first name, place and date of birth
This committee must provide the government with its final report by July 1, 2011.
