well, this is interesting,
Called the Data Commissioners Office asking a series of questions about the duty of a normal company in keeping accurate records, how far you have to go to ensure accuracy and they were quite strict, you have to go to reasonable lengths, but 'reasonable' is quite close to 'certain' that its accurate, you have make sure...
Called them again asking what the CRA's have to do and the answers are very very different.
It took me 20 minutes discussion to get the advisor I spoke to to admit that they are in fact data controllers - I was surprised about that so called them again on just on that very subject and got the same response, "no see, they aren't data controllers they are data processors" - only arguments about their credit scoring and advisory roles (and "Oh look I'm on your website and
equifax
is registered as a Data Controller") made the Information Commissioner`s Office admit that CRA's infact are data controllers.
On the subject of checking accuracy I was told that all the CRA's have to do is 'ask if the company' is comfortable with putting a default on the file', far less than the steps I was advised would be necessary for any other company.
Interestingly I was also told that what the CRA's say in their standard responses about their role under "Schedule 2... " is a "Red Herring" that in fact all that means is they can hold information until its proved innaccurate and as long as it does no harm"
On the amount of time information can be held, - it will be different in each companies case - 'as long as it is necessary and relevant' - which is pretty vague really, but I havent been able to obtain a record of when 6 years was agreed as industry standard for CRA's, the Information Commissioner`s Office didnt know when these discussions and agreements were made or what it was based on.
All in all, seems the DCO has different rules for the CRA's than any other company, and when I said that thats how it seemed, the advisor said "well yes, it is true to say that we handle CRA's slightly differently." which I think is astonishing! Definately a reason NOT to take a complaint about a CRA to the apparently biased Data Commissioners Office.