You would also probably find some wording about data being shared /
transferred to assignees, replacements and or transferees of the above
parties - the Data Controller(s). This should cover it but I would
expect that the original DC would have some duty to ensure that the
replacement agreed contractually to at least meet the same standards of
protection offered by the original DC.
Regards,
Clare
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-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Simon Howarth
Sent: 20 November 2008 16:12
To: [log in to unmask]
Subject: Re: [data-protection] When a credit card is taken over by
another bank ......
I would say that this is well covered from a consumer point of view, but
there may differences with employees as consumers...
Certainly Schedule 2 Para 6 would come into play in terms of "legitimate
interests". I feel certain that there will be some allowance in company
law with respect to such a transfer and as such would suspect it applies
to corporate situations also.
Simon Howarth.
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Teresa Gudge
Sent: 20 November 2008 14:34
To: [log in to unmask]
Subject: [data-protection] When a credit card is taken over by another
bank ......
Hi Everyone
If a corporate credit card is taken over by another bank and the product
changes from a Visa product to a MasterCard product then what does the
company need to ensure happens from a DP perspective ?
Without reading the contract with the first company I do not know if
there is a clause in there saying that if an employee agrees to hold one
of the credit cards and it is taken over by another bank then they are
happy for their details to be passed over - or does the company need to
request that employees apply to the new credit card company in order to
obtain the new credit card ??
I am trying to look at this from both perspectives - The Company are
obliged
to switch to the new product and do not want employees inconvenienced by
having their cards refused - but also they cannot just transfer all the
employee data to the new company.
Obviously I am recommending that many full and detailed communications
need to take place to employees - but where is the law strongest ? in
the take over by the other bank or in DP terms ???
Any guidance would be useful. Thanks.
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