2020-02-28
The Central Bank of Madagascar issued Instruction No. 001-DDI/2020 to amend Article 12 of its 2019 directive governing Credit Information Bureaus, mandating that supervised entities obtain free, informed, and explicit client consent before collecting, sharing, or using personal and credit data. The revised provisions require consent to be documented in writing or electronically with a "read and approved" notation, automatically covering future loans unless explicitly objected to, and extend to executive data of corporate clients. Supervised entities and Credit Information Bureaus must implement adequate staff training, verification controls, and AML/CFT and KYC due diligence to ensure compliant consent management.