Chris,
Do you mean you suggest making it part of the terms & conditions? Does this
then amount to making the transfer necessary for the performance of the
contract?(and therefore outside the application of the 8th principle)?
Gail
> -----Original Message-----
> From: [log in to unmask] [SMTP:[log in to unmask]]
> Sent: 29 May 2001 14:54
> To: [log in to unmask]
> Cc: [log in to unmask]
> Subject: Re: Debt collection agencies outside the EEA
>
> Gail,
> I would strongly suggest you do. Can I throw something else in the pot for
>
> discussion?
> Your debt collection agencey from time to time will have to track down the
>
> edbtors that have disappeared. Are they now determining the processing
> that
> takes place?. If yes are they now your joint data protection controller?.
> Does that make you jointly and severally liable with them? Do they have a
> licence under the consumer credit act 1974 to process debt? Have they
> notified the Information Commissioner that they are processing personal
> data?
> If no to any of the above does that make you jointly liable with them?
> Does
> it leave it open to the debtor to scream a breach of his human rights
> because
> there has been a breach of data protection therefore a breach of Article 6
>
> Right to a fair trial/Hearing.
> What about when that debt collector passes the tracing enquiry to an
> associate because it is out of his area.Does that enquiry agency become
> your
> data processor and should he use a part timer does he then become your
> joint
> data controller.
> Far fetched dont you believe it this is exactly how debt collection
> companies
> operate and have done for years. I await the groups feedback.
> Chris Brogan
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
If you wish to leave this list please send the command
leave data-protection to [log in to unmask]
All user commands can be found at : -
www.jiscmail.ac.uk/user-manual/summary-user-commands.htm
all commands go to [log in to unmask] not the list please!
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
|