Companies carrying out outdoor marketing activities : Must ensure proper handling of customers' personal data by marketing staff -- DPP4
The Complaint
A salesman of a pay television company visited a private residential building for a door-to-door promotion campaign. The salesman approached a man who was an ex-customer of the company. The man later complained to the Commissioner that the salesman had carried a computer printout recording the man's name and address but failed to take any steps to conceal the data so that anyone in the vicinity could easily read the data. The company however denied having sent any staff to conduct promotional activities in the building.
Findings of the Privacy Commissioner
Based on evidence available, the Privacy Commissioner satisfied that the salesman was an employee of the company and had carried out the promotional activities at the building. The salesman did hold a pile of paper containing the man's personal data when he visited the man's premises. It was also discovered that the company had not provided any guidelines to their marketing staff regarding the handling of personal data during outdoor marketing exercises. In the circumstances, the company was found to have contravened the security requirements of DPP4 in failing to take any reasonable practicable steps to ensure the proper handling of customers' personal data during outdoor marketing activities.
Action by the Privacy Commissioner
An enforcement notice was issued and the company was required it to devise a policy, practice and procedure regarding personal data security during the conduct of outdoor marketing campaigns.