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Gail, I would strongly suggest you do. Can I throw something else in the pot for discussion? Your debt collection agencey from time to time will have to track down the edbtors that have disappeared. Are they now determining the processing that takes place?. If yes are they now your joint data protection controller?. Does that make you jointly and severally liable with them? Do they have a licence under the consumer credit act 1974 to process debt? Have they notified the Information Commissioner that they are processing personal data? If no to any of the above does that make you jointly liable with them? Does it leave it open to the debtor to scream a breach of his human rights because there has been a breach of data protection therefore a breach of Article 6 Right to a fair trial/Hearing. What about when that debt collector passes the tracing enquiry to an associate because it is out of his area.Does that enquiry agency become your data processor and should he use a part timer does he then become your joint data controller. Far fetched dont you believe it this is exactly how debt collection companies operate and have done for years. I await the groups feedback. Chris Brogan