MIF 56 - Data Protection Consideration in Regard of DTC Flows

Current Status Closed Implementation Date N/A
Version Related Changes

Executive Summary

Whilst discussing DTC CP3313 Provision of Special Needs Customers’ Telephone Numbers, MDB_10_08 noted concerns with respect to:
  1. managing data protection when passing between parties’ personal data, especially when this contained third party contact information for vulnerable customers; and,
  2. when sending automated flows, establishing what controls need be in place to ensure that any data overwritten is accurate and relevant.
  3. MDB agreed that these were important design considerations for IREG, and with regards to data security it would be helpful to have a guidance note reinforcing parties’ responsibilities as Data Controllers, whilst for overwrites relevant parties will need to consider the form of their exception processing.
MDB also noted that there was a broader question as to how data protection considerations were managed for all flows, and MDB believed this was a matter for IREG to progress.

Change History

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