Phil,
Interesting questions. From what has been discussed, I would suggest that it could be either a breach or ok depending on the situation.
Here is how it could be ok. Caller contacts Company X. The listed telephone # is Fred. Caller contacts helpdesk (not the direct dial) "please put me through to Fred". That would not be a breach.
However, if the company is TPS registered and all numbers are listed, then it does not matter if the employee does not know about the number(s) that are or are not registered or even if the company is registered.
Best,
Lawrence
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Phil Bradshaw
Sent: 16 July 2015 12:49
To: [log in to unmask]
Subject: PECR - Corporate TPS
Fred's direct dial work number is registered with Corporate TPS.
John's number is not. Widget Salesman rings John . John says he does not deal with widgets but Fred does and gives salesman Fred's number. Behaviour I suspect many would admit to , in order to get salesman off our backs.
Salesman rings Fred.
Is this still a breach of PECR - unsolicited call where, in the words of Reg 21, the "number allocated to a subscriber [the company] in respect of the called line [Freds's line] is one listed in the register kept under regulation 26" ?
Or does John giving the number somehow makes it a solicited call ?
What if it was not John but the company switchboard?
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