Data Privacy

Headed by Vivenne Artz, OBE and Dr. Michelle Frasher, PhD, this group focuses on key privacy issues relevant to financial crime. 

About Us

The Data Privacy Experts Group draws on a global wealth of lawyers, practitioners, advisors and experts in the data, privacy and financial crime spaces. 

Global financial crime compliance (FCC) laws and regulations are multiplying and becoming more prescriptive.  Effective technologies and processes to screen customers and transactions to ensure compliance while meeting customer and investor expectations rely on the efficient and accurate processing of high volumes of data. 

Personal data, and especially sensitive data, referring to race or ethnicity, religious or philosophical beliefs, biometric data, and political opinions, is increasingly regulated.  However, both personal and sensitive data are foundational to FCC processes such as identity verification, customer onboarding, sanctions screening, transaction monitoring, risk assessment methodologies, and reporting.
The balance between FCC obligations that require obligated entities to learn more about customers and be proactive in fighting crime has been challenging to reconcile with data protection and privacy expectations that require the minimum of data to be collected, held and processed, and for specific and narrow purposes.  The complexities that exist between privacy and financial crime requirements need to be resolved to avoid legal and operational uncertainty.


The Data Privacy Experts Group is focussed on:

  • Identifying key privacy issues related to financial crime and AML regulations i.e. use cases, international data transfers, basis of processing personal and sensitive data, notice to individuals, subject access rights, retention and deletion periods, etc.

  • Offering examples of areas of uncertainty, lack of clarity and conflict in connection with privacy and AML obligations which are impacting firms’ ability to operate with certainty and effectiveness

  • Proposing recommendations for how to address areas of legal and regulatory overlap, and examples of existing legislation or regulation that could be leveraged by way of example  e.g. In some jurisdictions, public data does not carry personal data restrictions


Co - Chair Vivienne Artz OBE

Vivienne Artz is a strategic leader, advocate and expert on data and privacy global issues. She was previously a Managing Director and Chief Privacy Officer at the London Stock Exchange Group.  Prior to being a Chief Privacy Officer, Vivienne was a Managing Director and Global Head of Privacy Legal & Head of International for the Intellectual Property and Technology Law Group at Citi.  Before this, Vivienne practised as a solicitor in London, focusing on technology, privacy and commercial matters in three City law firms. 

Co - Chair Dr. Michelle Frasher, PhD

With 18 years of experience, Michelle Frasher is a leading expert in crafting databases and compliance processes for diverse jurisdictions. She specializes in the convergence of financial crime compliance and data privacy, authoring extensive publications on efficient data utilization and public-private collaborations. She was Director of Global Content at LexisNexis Risk Solutions and Sr. Director , Financial Crime Compliance Practice at Moody’s Analytics leading product development and regulatory strategy, and now serves as a strategic consultant.


There are currently no events specific to this group. To see the list of all upcoming and previous events, please go to the Articles and Events page


There are currently no publications from this group. To see the list of all previous publications, please go to the Articles and Events page