Data protection compliance can sometimes be seen as a blocker for organisations trying to do the right thing for their customers and so organisations involved in the financial services and gambling sectors will welcome two helpful pieces of guidance in this area issued last month.
Having worked closely with the Gambling Commission the ICO has confirmed that lenders should not be prevented from sharing information about customers with gambling organisations for the purpose of financial risk checks, provided that the checks are proportionate, communicated to customers transparently and DPIAs are carried out. In the longer term, the ICO is supportive of gambling industry plans to share information about high-risk customers who are gambling across multiple sites. The ICO’s full advice to the Betting and Gaming Council can be found here.
With interest rates rising steeply for borrowers, we have seen concern in the press and from Government that interest rate increases are not being passed on to savers. The ICO and Financial Conduct Authority (FCA) have issued a joint letter to UK Finance and the Building Societies Association which confirms that firms are not prevented from communicating with customers about savings interest rates by data protection law. Organisations can provide neutral, factual information about the rates and terms of savings products the customer currently holds, the interest rate and terms of other available savings products and their options for moving to other products, even when a customer has opted out of direct marketing. The ICO’s guidance on direct marketing and regulatory communications explains how to draft these communications without straying into direct marketing.
The full text of the ICO and FCA’s letter can be found here.
The ICO’s Guidance on direct marketing and regulatory communications can be found here.