How would you like to win "dream prizes"? The enticing questionnaire promises to "answer your dreams" by offering a whole host of goodies such as a Nissan Primera 1.6 SRi worth £17,000, a holiday for four in Disney World, Florida and £500 spending money, Sony Widescreen TVs, Dell Computers, etc. All you have to do is answer the questionnaire by next Thursday. But that questionnaire, sent out to one million people by PMI, stated to be a subsidiary of An Post, contains intimate financial and other intense questions, over 10 headings. These should not be answered unless the recipients want to give this intimate information to a database and face the prospect of being deluged with junk mail. Guidelines issued by the Data Protection Commissioner set out the obligations of data controllers. "Any failure to observe them would be a breach of the Act (Data Protection Act 1988)," according to the brochure detailing the guidelines.
On the fair obtaining and processing of personal information, the brochure says individuals should be fully aware of the following:
The identity of the persons who are collecting it (though this may often be implied).
the use to which it will be put
the person or category of persons to whom it will be disclosed.
The questionnaire explains: "We're using your answers to build up an accurate picture of the likes and dislikes of people like you. By doing this you can help ensure that companies only send you information that is of genuine interest to you."
It does identify PMI as the collector of the information. But it does not say that PMI is jointly owned by Equifax, an international database group. It is vague on what the information will be used for, though companies will obviously use the data to solicit people for business.
The identity of the users of the data is not disclosed. However, it can be deduced. Irish Permanent Finance features largely, as the survey says the car is sponsored by Autopoint, that is, in association with Irish Permanent Finance. Moreover, the questionnaire says in small print at the end that "certain sections of the above questions have been sponsored by Ocean, Irish Permanent, One Direct and Ireland Online", so these companies also appear to be involved. The guidelines are the ways a data controller achieves transparency and informed consent, which are the touchstones of fairness in data protection, according to the Data Protection Commissioner. So is the questionnaire transparent?
It does not indicate which companies are getting what information, neither does it give information about the sections that are not "certain sections".
The type of information being sought is virtually all-embracing. Here are some examples.
Your Name. You, and the other occupant, are asked to give name, age, marital status with pretty precise data on the average household income.
Your Home. Apart from normal questions like type of house and age of children, you are asked if you are planning to move and when.
Computers. You are asked about usage, who your server is, why you use it and what would entice you to go on-line,
Money & Investment. This is by far the most intense, with 56 questions, most of which have also to be answered by the second occupant. Apart from wanting to know the identity of your bank and which company has your mortgage, and where your savings are, it wants to know how many years are left on your mortgage and when your home contents insurance is due for renewal.
Newspapers and Radio. This is a readership and listenership survey.
Shopping. It wants to know how much is spent and asks for views on mail order. The questionnaire also asks for information on your car(s), its financing, precise information on telephone expenditure and even wants to know how big your cats and dogs are.
The data protection guidelines also say the data controllers should be able to answer yes to the information being "adequate", "relevant" and "not excessive". That raises the question: what is the relevance of asking about Fluffy, your cat, or Rover, your dog?
It could be argued that the questions are designed to ensure that the recipients receive only mail shots that are considered relevant. And some people might not mind being solicited. And if they want to be taken off that database, they can click the almost hidden box at the end. Also, under the Act, they have the right to be taken off any other database.
Others, however, would rightly take a strong contrary stance. Further, the questionnaire is not transparent. Why can't questionnaires specifically state what the data are for, who is going to use them, and who the data are going to be sold on to? Anything less is moving against the tide for greater transparency.
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