Bad quality master data increases the probability of missed hits; for instance, when matching customer names against names of politically exposed persons (PEP), relevant hits may be missed due to character encoding problems.

In banking systems, names are represented as sequences of binary digits (bits). The first name “Jim”, for instance, can be represented by three called ASCII characters:

"01001010" "01101001" "01101101".

Character encodings such as ISO-8859-1 and UTF-8 have different character representations, since ASCII cannot represent ä, ö, ü and other characters.

For example, the name “Jürg Näf” has different encodings in ISO-8859-1 and UTF-8.

"01001010" "11111100" "01110010" "01100111"

"01001010" "11000011 10111100" "01110010" "01100111"

"01001110" "11100100" "01100110"

"01001110" "11000011 10100100" "01100110"

The character encoding becomes compliance-relevant when a banking system uses simultaneously different types for legacy reasons. In this case, one encoding of “Jürg Näf” may match perfectly. However, if by mistake the UTF-8 encoding is assumed to be ISO-8859-1, 44% of the characters will not match (4 out of 9).

Generation of verifications for hits that differ by 40% or more, would obtain a significant number of false positives.

Data Protection Act

The Swiss Data Protection Act underwent a complete revision in 2020, and its new version took effect on September 1, 2023, along with the new Data Protection Ordinance (DPO). The revision itself is complete, but its practical application continues to evolve. The topic of AI is particularly relevant: On May 8, 2025, the FDPIC confirmed that the DPA is technology-neutral and applies directly to all AI applications. In practice, this means, among other things, that users must know whether they are interacting with AI (transparency requirement, Art. 19), and that a data protection impact assessment is mandatory in cases of high risk—such as profiling or facial recognition (Art. 22). The Federal Office of Justice (FOJ) is drafting a consultation document on AI regulation to be completed by the end of 2026. With this, Switzerland will implement the Council of Europe's AI Convention.

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