Comprehensive Customer Information vs Data Privacy

Apply privacy-by-design to AML data collection, gathering only risk-proportionate information and enforcing purpose-limited access with strong encryption.

CyberTRIZ analysis · Banking contradiction AML007 · one of 8,235 worked contradictions published by CyberTRIZ.AI

Regulations

EU_GDPR FATF NIST_PRIVACY_FRAMEWORK ISO_27001

Business Context

AML programmes require extensive customer information to understand ownership, business activity, transaction behaviour, and source of wealth. At the same time, privacy regulations require institutions to collect only information that is necessary.

Banking TRIZ Resolution

Apply privacy-by-design principles by collecting information according to customer risk, protecting sensitive data through encryption, and limiting access according to business purpose.

Recommended Banking TRIZ Principles

Principle 2 - Taking Out

Principle 24 - Intermediary

Principle 30 - Flexible Shells and Thin Films

Principle 39 - Inert Atmosphere

Expected Outcome

Better privacy protection

Stronger AML compliance

Reduced regulatory risk

Improved customer trust

TRIZ principles applied

P2 Taking OutP24 IntermediaryP30 Flexible Shells and Thin FilmsP39 Inert Atmosphere

Controls that address this (22)

EU_GDPR-CTRL-001 - Daily safeguarding reconciliationoperational · critical priority · Daily reconciliation between safeguarded customer balances, core ledger balances and safeguarded bank accounts. Variances above EUR 100 must EU_GDPR-CTRL-002 - Critical ICT incident reportingoperational · critical priority · All major ICT incidents impacting payment services, customer data or availability must be classified within 4 hours and reported under DORA EU_GDPR-CTRL-003 - GDPR breach notification workflowoperational · critical priority · Personal data breaches must be assessed within 12 hours and reported to the Belgian DPA within 72 hours where risk to data subjects exists.