CCR2 Risk, data, and GDPR
You should be very clear about who has
done the contacting and why. Often, I find that people have little understanding of the importance of why they are collecting and storing personal data.
Storing the correct information Knowing your customer is a major issue for the industry and, clearly, this can be a difficult issue, for example if you are buying debt and so are needing to rely on the originating creditor, but, nevertheless, the responsibility still goes all the way up the supply chain. You also need to be very clear in your
policy on what is actually meant by the deletion of information: will all information from records actually be deleted? At the moment, we see examples of where goneaway-customer records are partially blanked out.
Conclusion As I said at the start of this article, these are only intended to be some general
November 2017
You also need to be very clear in your policy on what is actually meant by the deletion of information: will all information from records actually be deleted? At the moment, we see examples of where goneaway- customer records are partially blanked out
know how the new regulations are going to be enforced. Indeed, this still seems to be somewhat
up for debate – in August Ian Cass, chief executive of the Forum of Private Business, insisted that many of his small-business members would not survive if a hard line was taken on implementation. “There is the potential for this legislation to impact the way many of these businesses operate and market themselves, and even force them to close down,” he said. But possibly the most likely view that the
Information Commissioner’s Office will take will be based on potential harm and, in this, our industry is very exposed because of the sheer volume and sensitivity of the data we process. The regulators will, no doubt, want to at
considerations as each organisation and sector will be different. And this work is all being carried out against a background where we do not really
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least see an organisation is exerting every effort to be compliant. So the time to act really is now! In summary, start to think about the
policies that need to be implemented and get ahead of the game! CCR2
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