Each time I find something interesting in the data the National Association of Commercial Finance Brokers (NACFB) collects as a by-product of its day-to-day work, I have to consider the data protection angle.
For instance, I’d like to compare specific exam pass data with the overall member data, to see if any one type of broker is any more likely to take, pass or excel at a particular exam.
By comparing and contrasting data sets, you can learn something that couldn’t be learned from just the one.
The trouble is, I’m reluctant to have members shouting “Data Protection!” at me, so I have to check I’m doing things right.
It’s a position we are all liable to find ourselves in from time to time, though in some ways things aren’t quite as restricted as they sometimes seem.
There is a distinction to be made between “sensitive” and “non-sensitive” personal data, and the NACFB only deals – with a few exceptions – in “non-sensitive” data: the sort of thing you would expect any organisation to pick up on.
If we were collecting racial or ethnic origin of a data subject, his or her political opinions, religious beliefs, trade union membership, physical or mental health or condition, or criminal offences or record, this is all considered sensitive.
The NACFB doesn’t hold any of this, for example, although we do credit checks and county court judgments. We classify those as sensitive for our purposes.
What might be of interest to brokers is the way in which, since the FCA stepped in two years ago, there has been a redoubled effort to scrutinise the processes within your office.
