23rd May 2012, 11:55 AM #1
More Data Protection
"We may provide your personal data and the data generated by cookies and the aggregate information to the vendors and service agencies that we may engage to assist us in providing you with the Vivo Miles service".
Some suppliers do use third parties and it's not wholly unexpected. However they seem a bit tighter on it (ParentPay for example specifically acknowledges they use a third party hosting company but they are quite specific in saying the hosting company has no access to the data). That clause for the Vivo service just says they can share it with anyone for any purpose they think is OK in providing their business (which might be hosting, but might equally well be marketing).
Am I being my usual paranoid self or would this ring alarm bells for anyone else?
23rd May 2012, 12:48 PM #2
If the company are telling you that they give you a cheap price for the service because it is off-set by income generated by using the data with these 3rd parties then you make a judgement about whether this is an acceptable compromise, but make sure that there are clear and contractual agreements about being told which companies, that it only gets done with your explicit permission and that 3rd party has to comply with *your* data protection policy as well. It makes it into a tri-partite agreement and has to be regularly reviewed ... but it can be done.
I have mentioned about a school putting into its Public Register entry about making use of third parties, marketing, etc ... but handing it to a third party where you have some control (legally and contractually) is different to handing it over to a third party where they have all the control and that includes handing it over to other third parties which you do not have any control either ... so you are not being paranoid ... just assessing the risk.
Thanks to GrumbleDook from:
23rd May 2012, 02:10 PM #3
@GrumbleDook : Thanks - that is helpful. I don't believe the company is giving a cheap price for the service on the back of selling on details, but their wording is a bit woolly about passing information on and the details they supplied about exactly what data their interface will extract is (must be) wrong. So I'm not very confident that (apart from anything else) they take DP very seriously.
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