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Question · Public sector undertakings and utilities

What about distributors, dealers and franchisees?

Short answer: Yes, you are responsible for what they do with your consumers' data

When distributors, dealers or franchisees handle consumer data for your service, they act for you, and you are responsible. Give them only what they need, add a data clause to agreements, train them, and check a sample every year. If a partner uses data for its own business, such as selling insurance, that is outside your purpose and must stop.

What the law says

Section 8(1) and 8(2) cover processors.

Steps

  1. List partner types and numbers.
  2. Issue a standard data clause.
  3. Give masked views where possible.
  4. Train partners.
  5. Check samples yearly.

Evidence to keep

Common mistakes

From each seat

What a good answer from management sounds like

“All partners sign the data clause, see masked data, and a sample is checked each year.” Effort and time: Medium · 3 to 6 months for a large network.

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