GDPR is nothing to do with surely.
and those ico guidelines were in-force at the time the DMP were entered into.
the DMP was still a short payment i'e not meeting the agreement signed upto
so both are a good case for arguing a default notice should have been issued at the time of the third payment that didn't meet the agreement and a defaulted date registered in the debt summary.
I then to always suggest people totally ignore the calendar markers as no-one can see them bar the debtor or the debt owner.
I defend no one as I do not indict, I merely report the facts as I see them. I am afraid you are blinkered probably by experience.
No ones fault.
When no creditor will forward the cash for the mortgage, for fear of someone justifying none repayment in this way, we have young couples with no chance in life, no home of their own.
Making excuses about the way loan debts are enforced, does not change this.
Loans have to be repaid, what you preach is a philosophy of despair.