15 March 2012
It was concluded that the core elements of the sale of the business did not breach the Data Protection Acts. However, the ODPC did note that, by notifying customers of their new service provider simultaneous to the completion of the sale but after the data transfer had occurred, it was not possible for the ODPC to come to the view that the “fair processing” requirements of the Data Protection Acts had been fully met by the Council in this instance.
On foot of the investigation, the Council also agreed to a number of undertakings before any debt collection data would be transferred from the Council to Greyhound. A more detailed note on the investigation is available on the ODPC website at www.dataprotection.ie.
Attribute to Catherine Allen, Partner, Public & Administrative Law, Mason Hayes & Curran. Contact Catherine at email@example.com or +353 1 614 5254.
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