The entry into force of Law No. 675 of December 31 1996, which included personal data protection rules, raised a number of doubts about the forms the banks must submit to customers to obtain their consent for the use of their personal data.
Following the intervention of the Authority responsible for the protection of personal data, which said that the forms used for the purpose by Banca Nazionale del Lavoro were not in line with the model forms, the latter have been approved by the Authority, according to which banks will not have to submit to it the forms used to obtain the customers' consent if they adhere to the ABI's suggestions. With the form prepared by ABI, the use of personal data by the bank must be related to the specific purpose of the transaction and service required by the customer. The circular then specifies what means may be used. With regard to the content of the form to be used by the bank to obtain the customer's consent, it is stressed that the customer must consent to the communication of any personal data to third persons. If consent is withheld, the bank has the right to perform only those transactions for which such communication is not required. In any case, the bank must indicate clearly which persons are authorized to use the customer's personal data in relation to the performance of bank transactions.