Arrows pointing backwards and forwards

Wealth screening: what’s compliant and what’s correct?

The ICO recently wrote to a number of universities to issue guidance on wealth screening, a practice we expressed some reservations about here on the Holly Palmer Consulting blog last year following a critical front page in the Daily Mail (you can read the MailOnline’s version of the newspaper piece here). The ICO’s letter was the conclusion to an investigation it undertook in response to that front page, and they’ve decided not to take any further action – a fact you can’t find on their website, although the letter was disclosed via a Freedom of Information request. You can find it here, together with a list of universities to whom the ICO wrote.

On the surface that would appear to be the end of the matter, and indeed the IDPE reported the story as such: “ICO to take no further action on wealth screening and data matching practices in universities”. But we think it would be a mistake to believe that the ICO has said there’s nothing to see here, as the conclusion to their guidance makes clear:

The ICO expects that any processing for the purposes set out above takes our guidance and advice into account. If we receive complaints in the future, any subsequent enquiries we make may lead to formal enforcement action.

So what does the guidance say, and what are its implications for our sector?

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