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OU Student Budgets Account Ltd uses a UK debt collection organisation which
in turns uses continental-based agents in respects of debts outstanding from
students outside the UK. One of these is in a non EEA country (Slovenia).
It seems to me that the dect collectors are our agents and  the contract
with them about how they process data needs to be reviewed. Presumably the
agents of our processors are our processors too? The credit agreement
already covers disclosures to debt recovery agencies. As far as the 8th
principle is concerned, do you think OUSBA Ltd need to go further and make
the possibilty of using non -EEA debt-collection agents part of the  terms
and conditions or obtain consent from students for this?
Gail Waters
OU DP Coordinator

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