Hi Scott,
I'm personally not aware of any formal "ban" by the ICO with regard to use of mystery shoppers in connection with credit or loan agreements. However the issue of the potential adverse impact of such activity on the mystery shopper is well known, and is explicitly referenced in the UK market research industry code of conduct, as well as having a brief mention in the industry guidelines for mystery shopping (copy attached).
Where such an exercise is proposed, we would need to consider the circumstances before deciding if we can or cannot support the mystery shopping exercise. For example, if the exercise is commissioned by a company involved in the industry that can arrange for the mystery shoppers credit reference files to be corrected after the exercise, then we may be able to proceed as it would be possible to carry out the project in compliance with the DPA by ensuring the mystery shoppers credit ratings remain unaffected. We would also ensure our mystery shoppers are clearly informed that if they agree to carry out the mystery shopping for this type of exercise, this would result in records of the applications made during the exercise being held by credit reference agencies and the financial institutions mystery shopped. Our mystery shoppers would therefore be fully informed prior to agreeing to carry out such an exercise.
I hope this is somewhat helpful. Happy to discuss in more detail with you off line if it would further assist.
Regards
Ian Barker
Head of Compliance & Information Security
T +44 20 7347 3318
M +44 7827 853494
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www.ipsos-mori.com
79-81 Borough Road, London, SE1 1FY
Knowing more about life, business and society
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Scott Sammons
Sent: 19 September 2012 09:57
To: [log in to unmask]
Subject: [data-protection] ICO View on use of Mystery Shoppers
A little birdy has informed me that the ICO has taken the opinion that the use of "mystery shoppers" on credit or loan agreements is against the DPA and discourages the use of them because they can result in a "search" being recorded against your credit file which could affect your ability to get finance in the future.
Is anyone aware of this guidance? If so, do you have a link to it.
I'm run a few quick searches of google and the ICO website and cannot find anything and unfortunately said birdy quickly flew away.
Thoughts are also welcome.
Many thanks,
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