A Complete View of Personal Data Protection in FinTech under ISO/IEC 27562:2024

Introduction

At the end of 2024 ISO/IEC jointly released ISO/IEC 27562:2024 “Privacy Guide for Information Technology – Security Techniques – Financial Technology Services.” The guide analyses all possible FinTech stakeholders, business processes that may involve personal data, and the impact of emerging technologies. Understanding the standard helps the financial sector fully implement national and regulator‑mandated personal‑information‑protection requirements.

Scope and Coverage

The guide defines FinTech as the use of ICT in all financial‑service functions, including banking, payments, and insurance, thus covering digital transformation. It positions personal‑information protection as a top priority for building trust in FinTech services.

Business‑Model and Role Analysis

Figure 1 (included) shows a generic FinTech service model. The guide identifies the following roles:

FinTech service provider – can act as personal‑information controller or joint controller.

Personal‑information processor – processes data on behalf of the controller.

Customer (data subject) – provides personal data for identity verification and enjoys user‑centric services.

Financial institution – banks, trusts, insurers, brokers, etc., that offer or consume FinTech services.

Regulatory authority – drafts and enforces legal frameworks for FinTech oversight.

The guide maps these roles to the ISO/IEC 29100 privacy framework, ISO/IEC 27701, ISO/IEC 29184, ISO/IEC 29134, and ISO 31000 risk‑management guidance.

Overall Privacy Principles for FinTech Services

Derived from ISO/IEC 29100, the guide lists eleven principles: consent & choice; lawful & explicit purpose; collection limitation; data minimisation; use, retention & disclosure limits; accuracy & quality; openness, transparency & access; participation & access rights; accountability; information security; and privacy compliance.

Privacy Risks per Role

Seven generic privacy threats are identified: linkability, identifiability, non‑repudiation, detectability, information leakage, lack of awareness, and non‑compliance. Specific risks include API‑related exposure, cloud‑computing‑induced threats, blockchain immutability challenges, and the consequences of data breaches (reputational loss, legal penalties, economic damage, etc.). Detailed risk lists are provided for each role (controller, processor, customer, financial institution, regulator).

Privacy Controls for Each Role

For service providers acting as controllers, the guide defines twenty‑seven controls, such as:

Policy compliance with data‑protection regulations.

Clear permission and consent mechanisms.

Legitimate purpose enforcement.

Strong authentication.

Controlled automated decision‑making with human oversight.

De‑identification techniques (ISO/IEC 20889).

Risk governance and management (ISO/IEC 29134‑based PIA).

Encryption of data at rest and in transit.

Cross‑jurisdiction transfer notices.

Malware‑prevention measures.

Breach‑reporting to regulators.

Security‑logging and monitoring policies.

Recovery and backup strategies.

Data traceability and provenance.

Explainable AI for automated decisions.

Processors receive a reduced set of basic controls (ISO/IEC 27002/27701) plus supplemental controls covering contractual obligations, confidentiality, data‑disclosure prevention, risk assessment, and privacy‑impact‑assessment procedures.

Customers (data subjects) are granted rights to access, correct, delete, and control their data, with mechanisms for meaningful consent, due‑diligence, data‑handling safeguards, anti‑re‑identification, anti‑discrimination, anti‑monitoring, and transparent information provision.

Financial institutions, as controllers, must limit processing to necessary purposes, record third‑party disclosures, manage cross‑border transfers, and enforce the same controls listed for service providers.

Participant‑Specific Privacy Guidance

The guide recommends a systematic risk‑mitigation strategy: identify and classify sensitive assets, implement access monitoring and IAM, apply encryption/ tokenisation/ de‑identification, define clear data‑disposal policies, and maintain business‑continuity and disaster‑recovery plans with regular testing.

Additional recommendations for controllers include limiting data handling to what is required, providing mechanisms for data‑subject rights, supporting privacy‑impact‑assessments, ensuring confidentiality obligations persist after contract termination, and maintaining robust technical and organisational safeguards.

Conclusion

By aligning FinTech services with ISO/IEC 27562:2024 and the referenced ISO privacy standards, organisations can systematically address privacy threats, implement concrete controls for each stakeholder, and achieve regulatory compliance while fostering trust in digital financial services.