The individual would be allowed to see the calculations which affect them? 
Can't think of the wording just now but I do recall there is provision for 
knowing how things pertinent to your relationship with the DC are 
calculated.

Also may be the case that the individual amounts are recorded in order that 
the organisation can make a decision on the settlement.  So if the debt is 
£1000 and they bought it for £500, they would accept £600 but not £400. 
They would need the net cost, not some blanket percentage across an 
aggregate set of debts, particularly when risk factors may affect selected 
records.

So in the case that the actual figure is recorded - if only to remove the 
need to calculate it when the settlement offer comes in - or to avoid any 
error because you also didn't record the percentage - is it now PD?

In the event that the percentage is not fixed then it surely must be 
recorded somewhere?  Or else you'd have no basis to consider any settlement 
below your absolute minimum risk debts.

The whole argument is based on aggregation which I just can't see working - 
you'd need it to remain constant across all debts for an indefinite amount 
of time for it not to need to be recorded.  And if it is then surely it must 
be accessible via SAR.

Ian




----- Original Message ----- 
From: "Phil Bradshaw" <[log in to unmask]>
To: <[log in to unmask]>
Sent: Friday, November 06, 2015 12:54 PM
Subject: Re: [data-protection] Debt value - PD?


Agreed - in part.

I've made some broad assumptions based on my understanding of how the debt 
market works. Obviously if they have bought a particular high value one-off 
debt based on a specific assessment there may be other arguments, but even 
there the PD involved would in my view be the characteristics and matters 
taken into account in setting the price - not the price itself.

So even in the broader case there might be an argument that in some cases 
the profile of debts purchased might be PD - with the obvious problem of how 
far can you say the average is PD of an individual - but again not the 
amount / %age  paid

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