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  1. Rather late in the day I've just noticed this document http://www.scoronline.co.uk/sites/default/files/high_level_prinicples_document_final.pdf which purports to set high-level principles for the Reporting of Arrears, Arrangements and Defaults at Credit Reference Agencies. You would think that this kind of document would be put together by the Information Commissioner after great thought and deliberation in his role as the guardian of the human right of privacy under article 8 of the Convention. Not so. This document was put together by the credit industry and then merely approved by the Information Commissioner who has been persuaded to write a foreword to the document in which he merely says that he will continue to express a "keen interest" in how personal data is processed by the credit industry. More amazing is the fact that this document which is drawn up by the credit industry – the very people that the Information Commissioner is meant to survey and to police, is intended to replace or supplement the Information Commissioner's own set of rules/guidance which he published several years earlier in 2007 -Data Protection Technical Guidance: Filing defaults with credit reference agencies I'm sure that some enthusiastic people will find interesting to make comparisons between the two documents. I will be interested to see what posts appear on this thread. However, one thing that jumps out at me is that in the 2007 document it says unequivocally that disputed accounts should not be the subject of credit file entries. In the 2014 document, it doesn't mention this but merely skirts around it by talking about accuracy. Also, in the 2014 document, I noticed that there is a requirement that 28 days notice be given before a default is entered. I'm not sure how this squares with the FAQ on the Information Commissioner's own website which says very clearly that a default without notice is generally not a problem. https://ico.org.uk/for-the-public/credit/ Is this delegation or abrogation by the Information Commissioner? high_level_prinicples_document_final.pdf guidance_on_defaults.pdf
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