Provision of data processing services

In line with the general criteria provided in 15 to 21, the provision of data processing services should be considered ancillary to banking, in any of the following illustrative situations:

• a. it supports banking, ensuring that banking operations are carried out effectively (e.g. development and/or maintenance of operating systems supporting the banking operations). The provision of such data processing services to other ASUs of the group should also be deemed as indirectly supporting banking;
• b. it complements banking, for instance, by enhancing, adding value to, or complementing banking products or services. Systematic cross-selling practices and common distribution channels should be taken into account in that respect; or
• c. it substantially relies on banking, for instance, where the data processing services significantly rely on data provided by or linked to the banking activities (e.g. provision of client payment data analytics).