GDPR Compliance in Milan

Milan is Italy's financial capital and the eurozone's fourth-largest financial centre, home to UniCredit (Italy's largest bank, €1.3T in assets, operating in 13 European countries) and Intesa Sanpaolo (€1.1T in assets, Europe's largest bank by market cap at certain periods). Mediobanca, the historic investment bank, and Generali (the world's third-largest insurer) are also headquartered here. Borsa Italiana — part of Euronext since 2021 — hosts the MIB index. Banca d'Italia (headquartered in Rome but with major operations in Milan) and CONSOB (Commissione Nazionale per le Società e la Borsa) provide banking and securities supervision.

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€1.3T
UniCredit total assets
€1.1T
Intesa Sanpaolo total assets
200+
Fintech District members
250,000+
Financial sector employees

Why GDPR matters in Milan

The General Data Protection Regulation (GDPR / DSGVO) governs the processing of personal data of individuals in the EU, with penalties of up to €20M or 4% of annual global turnover. In Germany, the BDSG (Federal Data Protection Act) adds national requirements including mandatory DPO appointment for organizations with 20+ employees processing personal data.

UniCredit, as one of only four G-SIBs headquartered in the eurozone and operating across 13 countries, must implement DORA at a scale that makes automation unavoidable — manual compliance would require hundreds of FTEs. Intesa Sanpaolo's acquisition of UBI Banca created one of Europe's most complex IT integration challenges, where DORA's ICT risk management requirements apply across legacy and modern systems simultaneously. Italy transposed NIS2 through Legislative Decree 138/2024, with ACN (Agenzia per la Cybersicurezza Nazionale) as the designated authority — adding a national layer on top of DORA. The Garante Privacy (Italy's DPA) has been one of Europe's most active GDPR enforcers, issuing €45M+ in fines. Milan's Fintech District, with 200+ member companies, makes it Italy's hub for compliance innovation.

Supervisory Bodies

Banca d'Italia, CONSOB, IVASS, ACN

Key Industries

  • Universal Banking & G-SIBs
  • Insurance & Reinsurance
  • Asset Management
  • FinTech & Payments

Notable financial institutions in Milan

UniCreditIntesa SanpaoloGeneraliMediobancaBanco BPMFinecoBankBorsa ItalianaNexi

GDPR Key Requirements

Lawful basis for data processing (Art. 6)
Data Protection Impact Assessments / DPIA (Art. 35)
Data subject rights management (Art. 15-22)
72-hour breach notification to authorities (Art. 33)
Data Processing Agreements / DPA with processors (Art. 28)
Data Protection Officer appointment (Art. 37, BDSG §38)