Prisma

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The GDPR – General Data Protection Regulation, intends to strengthen and identify data protection for all individuals within the EU. It comes into force in May 2018.

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IN THIS ISSUE:

Say what?
PRIIP KID Solution
GDPR
FinTech update
MiFID II
CSSF Circular on Cloud Computing
Being Involved in our Community
WIN conference: women and men
New branding, new website
What’s on in Luxembourg?

After some beautiful days in October, we must now accept the fact that summer is officially over and Christmas is just around the corner.

In our last newsletter of 2017, we’d like to remind you that we cannot only help you with your UCITS KIID creation but also, going forward, with the PRIIP KID production. If you have not thought about it yet, now might be a good time to contact us.

We also provide you with more details on the GDPR, coming into force in May 2018, and give you an update on MiFID II, FinTech and much more.

We continue to think about ways on how to assist you best and look forward to your feedback.

For now, and much in advance, I wish you a happy festive season, a wonderful end to the year 2017 and a fantastic start into 2018.

Äddi an Merci
Carole Miltgen
CEO
Luxembourgish word of the day: “Wéngert”

“Wéngert” means: Vineyard.

Automated PRIIP KID Solution
Be ready for the PRIIP KID challenge

The automated web-based solution ensures consistent structure and content across your KIDs, with the possibility to integrate data from your existing systems. The visual appearance of each KID will always follow your latest corporate identity requirements. Prisma will ensure that you are ready for the PRIIP challenge by making the PRIIP KID production easy and efficient. How can we assist you?

Automated PRIIP KID Solution

Be ready for the PRIIP KID challenge

The automated web-based solution ensures consistent structure and content across your KIDs, with the possibility to integrate data from your existing systems. The visual appearance of each KID will always follow your latest corporate identity requirements. Prisma will ensure that you are ready for the PRIIP challenge by making the PRIIP KID production easy and efficient.

Featuring automated data integrity checks, streamlined translation processes and pre-configured wordings in compliance with the EU Regulation, our PRIIP KID solution enables accurate and timely management of PRIIP KID production of any scope.

As the application date of the EU Regulation on Packaged Retail and Insurance-Based Investment Products (PRIIP) draws closer, the fund industry is facing many complex challenges. Our automated PRIIP KID solution will take away the headache and help you make the transition in a smooth fashion.

Our extensive project management expertise will further combine the best features of the automated solution with a highly professional human touch, including project monitoring, time management and quality checks.

You will receive a full-service suite that is tailored to your needs – from project setup to the distribution of the final PRIIP KIDs – providing distinct business advantages.

  • Reduced time-to-market
  • Mitigation of human error risks
  • Automated data input
  • High level of customisation
  • Output in diverse formats
  • Secure PSF-certified IT infrastructure in Luxembourg

For further information on our PRIIP KID solution, please do not hesitate to contact our team at prisma@prisma.lu
Please also refer to our new factsheet for details about our PRIIP KID solution.

GDPR – General Data Protection Regulation
On 25th May 2018, the General Data Protection Regulation, which will replace the Data Protection Directive (DPD) from 2002, will come into force after more than four years of discussions and negotiations. The GDPR was adopted by both the European Parliament and the European Council in April 2016. New regulation...

GDPR – General Data Protection Regulation

On 25th May 2018, the General Data Protection Regulation, which will replace the Data Protection Directive (DPD) from 2002, will come into force after more than four years of discussions and negotiations. The GDPR was adopted by both the European Parliament and the European Council in April 2016.

In order to address the new regulation, companies are currently analysing their data structure and processes.

The GDPR does not only apply to organisations located within the European Union, but also to organisations outside of the EU, provided that they offer goods or services, or supervise the behaviour of EU Data Subjects.

Any information related to a natural person or ‘Data Subject’, that can be used to directly or indirectly identify the person, is subject to the GDPR. This can be anything from a name, photos, email addresses, bank details, posts on social media, medical information, or even computer IP addresses.

Amongst others, the below special categories have been defined and certain rights have been strengthened with the GDPR.

  • Right to erasure (Rights to be forgotten)
  • Sensitive data (biometric and genetic data)
  • Right to data portability
  • Pseudonymisation
  • Restriction of processing
  • Profiling

A verifiable explicit consent from the Data Subject will be required and it needs to be obvious to the Data Subject what their data is going to be used for at the point of data collection. Companies need to be able to proof that they are GDPR compliant.

The GDPR has therefore defined several roles that are responsible for ensuring compliance: the data controller, data processor and the data protection officer.

In case of data breach, it is possible, that both the company and processing partner will be liable for penalties even if the fault is entirely on the processing partner.

Companies are further required to have a DPO if they process or store large amounts of EU citizen data, process or store special personal data, regularly monitor Data Subjects, or are a public authority.

Non-compliance with an order by the supervisory authority is subject to high administrative fines of up to 20 million EUR, or up to 4 % of the total annual turnover of the preceding financial year, whichever is higher. A substantial amount compared to previous years' fines, which were around 500 EUR.

FinTech update
Already a globally recognised financial centre, Luxembourg has continued to strengthen its position as a world leader in the sphere of digital financial services throughout 2017. Get the latest update on FinTech in Luxembourg

FinTech update

Already a globally recognised financial centre, Luxembourg has continued to strengthen its position as a world leader in the sphere of digital financial services throughout 2017.

While there have been considerable FinTech developments in fields such as fund technology as well as financial inclusion, the so-called RegTech (regulatory technology) is viewed as a particularly promising growth area by regulators and institutions alike.

The LHoFT (Luxembourg House of Financial Technology) Foundation was officially opened in April 2017. LHoFT is a public-private joint venture with a goal to boost technology innovation for Luxembourg’s financial services industry, as well as to attract more and more global FinTech leaders to Luxembourg.

The second-ever Luxembourg FinTech Awards were handed out in Kirchberg this summer. This year’s competition had more than doubled in scope as compared to its first edition in 2016, suggesting a growing appetite for FinTech opportunities and investors.

To navigate and categorise the Grand Duchy’s growing FinTech ecosystem, the Luxembourg Bankers' Association (ABBL) has launched a website in October 2017, which covers all FinTech companies in Luxembourg. ABBL’s directory currently includes over 300 organisations and is intended to help potential clients find new local service providers.

For further information and solutions tailored to your needs, please do not hesitate to contact our team at prisma@prisma.lu

MiFID II application date is soon approaching
While MiFID II will come into force in January 2018, there are serious concerns about the industry’s readiness for MiFID II ahead of the January 3 deadline, leading firms to hope that regulators take a tolerant approach. What’s the latest?

MiFID II application date is soon approaching

While MiFID II will come into force in January 2018, there are serious concerns about the industry’s readiness for MiFID II ahead of the January 3 deadline, leading firms to hope that regulators take a tolerant approach.

Regardless of widespread concerns about a deficiency of market readiness for the comprehensive directive, the European Commission has ruled out delaying the implementation of MiFID II.

The commission previously approved a delay of one year after the industry asked for more time to comply.

MiFID II comes into force on January 3, presenting extensive new directives in areas such as inducements, trade reporting and product governance.

In the past few weeks, market participants and regulators have advised, that companies might have issues in complying with the directive within the current deadline. Some have urged for the implementation date to be pushed back due to the complexity of the rules.

Furthermore, senior regulatory policy advisers at the European Fund and Asset Management Association presumed that the initial implementation of the directive will not be faultless.

A special European MiFID template (EMT) has been created by a European working group and approved by EFAMA which includes explanation on what information are now required with the new directive and can be used for the exchange of information between the asset managers with the distributors.

The MiFID II package introduces a series of procedures, to address consequences of MiFID I and problems raised by the financial crisis, such as improving investor protection, increasing the efficiency of the financial markets and making these stronger and more transparent.

MiFID II combines the Markets in Financial Instruments Directive (MiFID) and the Markets in Financial Instruments Regulation (MiFIR).

IT outsourcing based on cloud computing infrastructure
The fast-developing IT world has not only created new technical possibilities, but also a need for a constantly adapted legal framework. On 17 May 2017, the Commission de Surveillance du Secteur Financier (the CSSF) has therefore issued four circulars which do not only replace existing legal requirements in relation to IT outsourcing, but also cover new topics such as the IT outsourcing based on cloud computing infrastructure. Up in the clouds...

IT outsourcing based on cloud computing infrastructure

The fast-developing IT world has not only created new technical possibilities, but also a need for a constantly adapted legal framework. On 17 May 2017, the Commission de Surveillance du Secteur Financier (the CSSF) has therefore issued four circulars which do not only replace existing legal requirements in relation to IT outsourcing, but also cover new topics such as the IT outsourcing based on cloud computing infrastructure.

The new circular 17/654 addresses concerns in relation to the protection of sensitive data and the implementation of cloud based solutions in Luxembourg. It defines characteristics, service models and deployment models for such solutions and introduces new legal requirements in order to help mitigating associated risks and provide further guidance.

Cloud computing solutions are defined as in-scope of the new circular when they meet the following criteria: on-demand self-service, broad network access, resource pooling, rapid elasticity and measured service. They are usually offered by service providers as Infrastructure as a Service (IaaS), Platform as a Service (PaaS) or Software as a Service (SaaS) with the following deployment models:

  • Private cloud
  • Community cloud
  • Public cloud
  • Hybrid cloud

If all five essential characteristics are met and if the service provider's staff has no access to the customer's data and system, unless the customer exceptionally provided a prior consent and the access can be monitored, the cloud solution will qualify as cloud computing solution under circular 17/654. From a technical point of view, resources should be managed daily and automatically, i.e. without manual intervention.

The cloud computing circular foresees different roles and scenarios for the IT outsourcing process and provides further guidance to the ISCR, i.e. the consumer of such cloud based service, regarding the following aspects:

  • Governance
  • Customer information and consent
  • Prior CSSF notification and authorisation
  • Outsourcing risk management
  • Business continuity
  • System security
  • Service contract
  • Monitoring mechanisms
  • Right to audit

The new cloud computing circular applies to financial professionals such as, but not limited to, investment firms, specialised and support PSFs, payment and credit institutions.

For further information on the above, please do not hesitate to contact our team at prisma@prisma.lu

Rugby Summer Camp in September 2017
The RCL is working closely with Caritas. Refugee children as well as children from families in need, and kids from the Dreiborn youth offenders centre participate for free; therefore, the RCL needs sponsors like us allowing them to pay for these little ones. This way for charity

Rugby Summer Camp in September 2017

The RCL is working closely with Caritas. Refugee children as well as children from families in need, and kids from the Dreiborn youth offenders centre participate for free; therefore, the RCL needs sponsors like us allowing them to pay for these little ones.

We supported and sponsored the Rugby Club Luxembourg Children Summer Camp. The Prisma RCL rugby summer camp took place from 28 August to 1 September 2017 at Stade Boy Kohnen. For 5 days, children between 8 and 18 years participated in pre-season Rugby drills and activities, expertly guided by professional coaches Eugene McCarthy and Willy Shubert from Ireland, former Harlequins winger Danny Ligari Badham and Luxembourg’s own Scott Browne.

With the donation of 3,000.00 EUR, Prisma supported the pre-season training camp, which is organised each year. We have therefore decided to support the initiative to allow those children to participate for free.

Teamwork, Respect, Enjoyment, Discipline and Sportsmanship are rugby values which we share. We applaud and appreciate that the team includes everybody, irrespective of their background. We very much support inclusion and helping those in need.

Next to this summer camp and in addition to working with Caritas, the RCL also works with the Schrassig and Givenich prisons and the Dreiborn Youth Offenders Center. RCL players go into these institutions and teach them rugby. Without any preconception and without necessarily knowing their stories, they meet them, just like meeting any other team player and spend a few hours together with them, playing rugby. By receiving respect and a moment of happiness, it allows the prisoners/offenders to take their minds of their daily life and possibly dream of a better future.

Inauguration playground Mathëllef on 11 July 2017
Every year, instead of giving individual gifts to our clients, we contribute money to a specific charity project. Prisma donated 2,200 EUR to Mathëllef Asbl. Thanks to our donation, in 2016 of 2,200 EUR, Mathëllef could build a playground, which was inaugurated on 11 July 2017. We are very happy and proud about the result and hope the children enjoy their new play area. Escape isolation...

Inauguration playground Mathëllef on 11 July 2017

Every year, instead of giving individual gifts to our clients, we contribute money to a specific charity project. Prisma donated 2,200 EUR to Mathëllef Asbl. Thanks to our donation, in 2016 of 2,200 EUR, Mathëllef could build a playground, which was inaugurated on 11 July 2017. We are very happy and proud about the result and hope the children enjoy their new play area.

Mathëllef ASBL offers support and therapy to mentally disordered people. Mathëllef is helping them to escape isolation by allowing them to be part of the so-called normal world again. At the therapeutically farm Mutferter Haff a dedicated team of professionals is supporting psychic people with their daily struggle to live. As Mutferter Haff is open to everybody it strongly encourages the encounters between affected and unaffected people. Every person deserves the feeling of respect, companionship and recognition. We therefore support Mathëllef who fight against ignorance and give the feeling to people with psychological illness, that they are not worthless but that they belong to our society, just like everyone else.

“Men are from earth, women are from earth. Deal with it” This was the topic of a presentation that I recently gave to women and men. Face the facts...

WIN conference: women and men

“Men are from earth, women are from earth. Deal with it” This was the topic of a presentation that I recently gave to women and men.

Much has been said on this topic already and some say (I include myself in this group) that the discussions went over the top and that the whole topic has turned into a non-event.

The fact remains that some women still feel that they are not respected in the same way that men are. They suffer daily under the consequences. Is it because men treat them differently or is it because women allow them to treat them differently? Are women, among themselves, kinder to each other or are they worse? Many questions and depending on who you ask, many answers.

What makes the difference? The below stereotypes are supposed to give us an idea. I can only speak for myself and must agree with some but also strongly disagree with others (Dependent… ha! As if!)

The narrowest gender pay gap is in Slovenia with “only” 3,2%, Estonia on the other hand must make an effort. Luxembourg can be found in the top 10.

During my presentation, we spoke about how women feel this lack of equality. Some had stronger feelings about it than others. Some women rather want the right work/life balance, don’t want to be in the office for hours without end and happily accept less money and less responsibility; if that means that they can leave the office at a reasonable hour.

Others felt that they worked very hard to get this manager job, which they never got because a male colleague would always be favoured, despite all her efforts. In a perfect world, the right person should be selected for a job, irrespective whether it is a man or a woman, but then again, we don’t live in a perfect world...

Eleanor Roosevelt once said, “No one can make you feel inferior without your consent”, I fully agree with her. Don’t let anyone do that to you!

“A change is as good as a rest”, so the proverb says. Since we don’t get much rest, we decided on a change. Get a glimpse...

New website, new branding

“A change is as good as a rest”, so the proverb says. Since we don’t get much rest, we decided on a change.

We teamed up with some great artists to change the face of the company.

We have recreated and re-branded our documents, our business cards and most importantly our website. Feel free to visit www.prisma.lu and give us your feedback.

We hope you like it!

Walfer Bicherdeeg
18 November 2017 - Walferdange, Luxembourg

International Bazaar
25 November 2017 and 26 November 2017, Luxembourg

Winterlights
23 November 2017 until 02 January 2018, Luxembourg
            Tourism Fair "Vakanz"
12 January 2018 until 14 January 2018, Luxembourg

Springbreak
21 March 2018 until 25 March 2018, Luxembourg
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