6
Business
Regulation
70
Worldline
2016 Registration Document
Compliance with technical standards
6.9.4
applies to devices that require the entry of a PIN. The aim of this
Entry Device standard (“PCI-PTS,” formerly PCI-PED), which
always processed by payment acceptance devices in a manner
standard is to guarantee that cardholders’ confidential PINs are
transaction security. Other PCI-SSC standards have emerged,
that is fully-secured and to ensure the highest level of payment
Standard) aimed at preserving the confidentiality of payment
including PCI-DSS (Payment Card Industry – Data Security
unattended payment modules). The development of these
transaction data and PCI-UPT (security standard specific to
Payment services providers, and, in particular, terminal
standards, including, in particular, standards established by the
manufacturers must comply with a number of security
These security standards seek to improve payment card data
Payment Card Industry – Security Standard Council (“PCI-SSC”).
apply to the various components of payment card transactions.
security by adopting a broad range of specific standards that
The main such standard is the Payment Card Industry – PIN
requirements, is managed by the PCI-SSC’s founding members:
standards, which requires continual modifications to existing
consultation with other electronic payment industry players
Visa, MasterCard, JCB, American Express and Discover in
banking associations, banks, processors, etc.). This system thus
(payment terminal manufacturers, regulatory bodies, retailers,
standards and the rules established to implement them. The
allows companies to participate in the development of
standardization.
Group participates in the European working group on protocol
By way of example, the Group has obtained the PCI-DSS
for its secure online payment platform and its Pay-lib service
(Payment Card Industry – Data Security Standard) certification
that the cardholder’s confidential data as well as any sensitive
(cloud-based electronic wallet). This standard aims to ensure
and databases level.
transaction data are always securely processed at the systems
Lastly, the Group is subject to international security
environmental requirements for technological infrastructure.
card security, established by the Europay MasterCard Visa User
requirements such as the international standard for payment
Group
(“EMV User Group”), in which the Group participates.
such as ISO
9001, which relates to requirements for quality
The Group is also subject to international certification standards
management systems and ISO
14001 which relates to
Protection of personal data
6.9.5
In connection with its business activities, the Worldline Group
protection laws and regulations in Europe as well as in other
collects and processes information subject to personal data
data processing is carried out on behalf of both Worldline Group
regions in which the Worldline Group operates. Such personal
companies themselves and their customers.
Personal data processing within the
6.9.5.1
European Economic Area
Directive 95/46/CE of October
24, 1995 (the “Personal Data
regulation within the European Economic Area (the “EEA,” which
Directive”) is the point of reference for personal data protection
Liechtenstein). In France, the Personal Data Directive was
includes the European Union, Iceland, Norway and
January
6, 1978, which relates to information technology, filing
implemented through various amendments to law no.
78-17 of
been adopted through law no.
2004-801 of August 6, 2004.
system and civil liberties, with the main amendment having
data is included or is meant to be included in a filing system.
natural person who has been identified or is identifiable directly
“Personal data” is broadly defined as all information relating to a
nationality. The Personal Data Directive requires persons and
or indirectly, regardless of his or her country of residence or
incorporated in an EEA member state or have recourse to data
entities responsible for processing personal data that are either
number of measures prior to and at the time the relevant data is
processing functions in an EEA member state, to put in place a
collected, while it is stored and until it is erased. According to the
non-automated personal data processing when the relevant
The Personal Data Directive applies to automated or
with others, determines the purposes and means of the
Personal Data Directive, the person or entity that, alone or jointly
subcontractor acting on behalf of a third-party), is considered to
processing of personal data (as opposed to a simple
be a “data controller”.
With respect to each of its activities that involve personal data
analysis on a case by case basis in order to determine whether it
processing, each Worldline Group entity in Europe conducts an
is acting in a data controller or subcontractor capacity.
(for instance those entities that handle employees’ personal data
or anti-fraud measures), it is subject to the following obligations:
Where a Worldline Group entity functions as a data controller
to satisfy the criteria set forth in the Personal Data Directive
●
among others, that the person concerned has given his or
for making data processing legitimate, which include,
for the purposes of pursuing a legitimate interest or for the
her consent or the processing of personal data is necessary
a party;
performance of a contract to which the person concerned is
to ensure that the personal data is (i) processed fairly and
●
purposes, and proportionate for such processing and/or
lawfully, collected for specific, explicit and legitimate
kept up-to-date;
collecting purposes, and (ii) accurate and, where necessary,