The BBC say that they get the phone details from a range of third parties.
Some these Third Parties, as far as I can see have made a disclosure of
personal data - as they are likely to hold the name and mobile phone number.
I am not sure if the Mobile Phone Directory Service have received personal
data as they might not have any other information in their possession that
identifies the individuals concerned - or likely to get such details.
The PECR regulations require consent for a marketing call to an individual
subscriber. However it will be the user of the service that makes the
marketing call. Clever n'est ce pas!
My first conclusion. I think the person who has the most main data
protection worries would be the source of phone numbers to the Mobile Phone
Directory Service; that person has the phone number and the individual
subscriber. What they say on their fair processing notices becomes very
important.
Does anyone know for certain whether the Mobile Phone Directory Service are
assuming that it does not hold personal data?
By the way, this definitional analysis is standard fare for our data
protection courses as well as an appreciation of all things from Barnsley;
www.amberhawk.com for details.
C
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