Response to consultation paper on use and sharing of personal information in the public and private sectors – by British
BBA response to a consultation paper on the use and sharing of personal information
in the public and private sectors
The British Bankers’ Association is the leading UK banking and financial services trade
association and acts on behalf of its members on domestic and international issues.
Our 225 banking members are from 60 different countries and collectively provide the full
range of banking and financial services. They operate some 130 million accounts, contribute
£50bn to the economy and together make up the world's largest international banking
The financial institutions represented by the BBA hold 130 million accounts. This represents
a significant share of the total volume of data held on computer systems in the UK. Financial
institutions work closely with credit reference agencies (CRAs) and data relating to the credit
records of customers is shared across the finance industry via the three agencies.
Members of the BBA welcome the opportunity to provide an industry response to this
consultation. This response represents the collected views of members although some
members will be submitting their own individual response.
The extent of data sharing already taking place is discussed in this response and we refer to
the views of the industry already noted in response to the BERR consultation on whether or
not the Government should introduce specific legislation to enable the sharing of non-
consensual credit account data with CRAs. This is data not currently shared with CRAs by
many lenders because ‘consent’ may not be held. We consider legislation which expressly
permits such data sharing would be of great benefit to the industry and greatly assist their
obligations to lend responsibly, although we are of the view that there is a strong argument
to suggest that such data sharing can occur under the legitimate interests provision within