Schedule 7, paragraph 7 applies to the intentions of the DC in relation to any negotiations with the DS.
No negotiations or no stated intentions, no exemption.
M
Sent from my iPad
> On 7 Nov 2015, at 07:39, Tim Turner <[log in to unmask]> wrote:
>
> Even if it's personal data (and I don't agree that it is), surely it would be exempt from a SAR under the negotiations exemption?
>
> Tim Turner
>> On Sat, 7 Nov 2015 at 02:43, Ian Griffiths <[log in to unmask]> wrote:
>> 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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