The UK Finance Strong Customer Authentication Programme Management Office have previously communicated the FCA endorsed position of card issuers adopting behavioural biometrics as their second factor to One Time Passcode. To support industry and provide additional guidance, the UK Finance PMO wrote, with help from the industry, to the Information Commissioners Office (ICO) to obtain guidance on a GDPR concern. Links below provide context on the request made to ICO for guidance, their response, and a summary paper produced by UK Finance SCA PMO legal counsel (Osborne Clarke).