"That begs the question of how the DC can identify which of two individuals supplying identical address, email and telephone details is *the* subscriber."
Do you need to distinguish in this context for PECR? If A is the subscriber, is not B the agent of A so far as you are concerned if A has given B access?* Act on the last instruction and let them sort out the mess.
* Perhaps sensible to provide for this specifically in T&C for avoidance of doubt.
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