A customer 360 banking data model: entities, identity keys, survivorship rules, retention, PII tags, sample schemas, event taxonomy and how BIAN maps.
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By Art Kukharenko · Published · Updated
A customer data platform (CDP) connects customer records, consent and events for banks and financial firms. PrivyCDP runs in your datacenter or cloud account. Your team controls access and encryption keys. Use these guides to assess data flows, audit records and operating duties.
Scroll horizontally to compare all columns ↔
| Regime | What it touches | Effect on a customer data platform | Read more |
|---|---|---|---|
| DORA (EU) 1 | Register of information, contract terms, exit strategies | The platform is a register entry whether SaaS or licensed on-premise software; the contract must state data locations and return | DORA and your marketing stack |
| PCI DSS v4.0.1 2 | Cardholder and authentication data | Card numbers and authentication data stay out of the platform; tokens are issued upstream | PCI DSS v4 and marketing data |
| GDPR 3 | Purpose limitation, retention, objection, automated decisions, transfers | Consent ledger, retention per purpose, region pinning | Customer 360 data model |
| US GLBA and bank regulators 4 | Security programme, vendor oversight | Encryption, contractual limits on vendor use, oversight | Regulatory frame for banks |
| UK FCA and PRA 5 | Outsourcing, operational resilience | Termination, access and continuity on exit | UK outsourcing rules |
| APRA CPS 230 and CPS 234 (Australia) 6 | Service provider management, information security | Material provider register; data ownership and audit terms | APRA service provider rules |
| EU AI Act 7 | Credit scoring is high-risk from 2 December 2027; marketing personalisation generally is not | Keep credit-related scoring inside model governance | Next best action inside the bank |
This table is a map, not an opinion on any institution's obligations. Each satellite page cites the primary texts.
The pattern PrivyCDP uses with banks keeps the customer data path inside infrastructure the bank owns. The components are an identity graph with deterministic stitching, a decision engine that runs inference in the perimeter, an append-only consent and audit ledger, and channel orchestration for email, SMS, push and branch. Keys are issued and rotated by the bank's own key management, and outbound traffic to advertising, marketing-technology and public analytics endpoints is blocked by default. PrivyCDP runs as licensed software; the bank operates the infrastructure 8.
Two arrangements are common. In the first, the platform is installed in a bank-owned VPC under the bank's identity and access controls. In the second, a hybrid, the core data plane (identity resolution, audit ledger, policy plane) runs on-premise and edge orchestration and inference run in a private cloud region 9. A sovereign or air-gapped option is listed for stricter requirements 9.
The anonymised Tier-1 European bank reference describes the first arrangement: installation on-premise in a bank-owned VPC, a unified profile graph across retail, wealth and corporate banking, AI-assisted segmentation inside the boundary, activation only to internal systems, no customer-data egress, and a fixed three-year cost model 10. Permissioned references and release-specific evidence can be requested during evaluation 8.
A self-hosted platform is not right for every institution. A bank without a platform engineering team, or without a residency or key-control requirement for the data in scope, may be better served by a vendor-operated service with a contract that meets DORA Article 30 or its local equivalent.
To test fit for your institution, complete the deployment qualification form; it records the workflow, boundary, scale and ownership questions in one place.
A customer 360 banking data model: entities, identity keys, survivorship rules, retention, PII tags, sample schemas, event taxonomy and how BIAN maps.
Updated
A customer data platform for banks must keep identity, consent and audit under bank control. Failure causes, regulation map, egress guide, 20-point checklist.
Updated
Next best action in banking: eligibility, propensity, arbitration and suppression, latency budgets, model risk, EU AI Act limits, and inference inside the bank.
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Put this evaluation into practice.
Assess your deployment requirementsThis page is general information, not legal advice.
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