A good thought Tim.
However, we are comfortable that the customer has freely provided the
authority to sanction the provision of information (we also know its in
their interests to do so as the reason for the requests are to attempt
to find a way to legally abstract them from their contractual liability
to make payments to us).
We believe that the proofs are in deference to our bank status and the
"know your customer" requirements. However, we just don't apply their
provided proof in our calculations as we check via our own internal
processes and documentation before we issue the customer information.
Do you think then, that even if we receive sufficient information,
payment and authority that we should still send the data to the customer
direct, not the third party? I'd be interested to know your views on
this and why.
Even if we declined on the basis of the DPA, we'd still have to provide
it on the basis of the Section 107 of the CCA.
They get us all ways......
Regards,
Clare
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________________________________
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Tim Trent
Sent: 23 February 2009 14:00
To: [log in to unmask]
Subject: Re: [data-protection] Proofs supplied for a SAR by a Third
Party
I don't quite understand how a SAR can be issued against you by a third
party with or without consent. Naive me thinks they are personal, and
may even consider one to release information to a 3rd party as forced
consent
Clare Watts wrote:
Dear List members,
I'm getting increasingly concerned by the number of Subject
Access Requests
we receive from third party's with our customer's
consent/authority.
--
________________________________
Tim Trent - Consultant
Tel: +44 (0)7710 126618
web: ComplianceAndPrivacy.com - where busy executives go to find the
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