Mexico City, April 5th, 2021.


As of March 23rd  of this year, Financial Institutions are obliged to collect and retain geolocation data in real time of users who open accounts, enter into contracts or carry out operations through digital platforms. This, in accordance with the Resolution that reforms, adds and repeals various general provisions referred to in article 115 of the Credit Institutions Law, published in the Official Gazette of the Federation on March 22nd, 2019.


The measure seeks to contribute to the prevention of so-called money laundering and terrorist financing, as well as to provide security to users. However, it is questionable from a data protection perspective, taking into account the principles that govern this matter, particularly the principle of proportionality.


The National Institute of Transparency, Access to Information and Protection of Personal Data (“INAI”) issued a statement in this regard and asked the Financial Institutions to take extreme precautions with respect to the processing of real-time geolocation data of their users. The INAI’s statement is available (only in Spanish) at the following link: Comunicado INAI-097-21.pdf.


The ​​Privacy and Data Protection Practice of the firm will be pleased to provide any additional information.


S I N C E R E L Y,


Adolfo Athié


Renata Buerón


Erika Rodríguez