Neutral comparison
What each side says
This page does not declare a winner. It places each side's position next to the question that remains unresolved.
Visibility of Product B
Complainant position
Information concerning another financial product was referenced during a collection call concerning Product A.
The institution states that processing by its appointed service provider occurs on its behalf, may rely on contractual necessity, and is subject to access controls.
Unresolved question
Whether the access and actual use of Product B information during the specific interaction remained within the lawful, necessary and authorised scope.
Legal basis
Complainant position
The complainant asked which specific lawful basis covered the processing of Product B data during a Product A task.
Contractual necessity was described as the basis, with consent stated as not required for processing necessary for the stated purpose.
Unresolved question
Whether a single basis can cover data relating to a separate product and contract.
The original recording
Complainant position
The original recording, call logs, access logs and audit logs were requested so the account of the call could be verified.
The position relayed was that the original audio also contained personal information relating to another individual.
Unresolved question
Whether the third-party information could be masked, muted or redacted so the recording could still be verified.
Ownership of the process
Complainant position
The complainant challenged whether the regulatory responses adequately addressed the evidence requested.
Responses were issued through complaint-handling and supervisory channels.
Unresolved question
Which body owns the resolution when a matter moves between controller, processor, regulator and another authority.