Broadly, the UK and EU regulatory environment impacts Telrock two ways; directly due to the nature of our Operations, and on our Product.
What does Brexit mean to Telrock? Very little at a Product or Operational level – Telrock operates in EU countries so Telrock will need to comply with all EU regulations in any case. For operations within the UK, with regards PSD2 and GDPR – the Government has confirmed that Brexit does not impact the commencement of GDPR or PSD2. So no change there.
It is not surprising that the UK Government isn’t changing course with PSD2 or GDPR. The statutory objectives of consumer protection, effective competition, market integrity, of the FCA are congruent with PSD2 and following GDPR is congruent with the ICO strategy. A deregulation agenda, with sound bites of “cut red tape” would be swimming against opinion in the wake of Grenfell, the GFC, and consumer mistrust of Banking.
Operationally, Telrock send Electronic communications (SMS, Email), and we process consumer data. Around communications, we are governed by PECR (The Privacy and Electronic Communications Regulations 2003) which implements a 2002 EU Directive known as the “e-privacy Directive”. With processing consumer data in the UK, this means the ICO and the “The Data Protect Act 1998” and GDPR.
Though there isn’t any UK legislation to mirror EU Regulation GDPR UK (as there is with Payment Service Regulations), the Government has said that “The Great Repeal Bill” EU law will be domesticated into UK law, so EU Regulations will be codified into UK Law. The EU Article 29 Working Group produces reports and opinions on GDPR, and the UK ICO further interprets GDPR.
At a Product level, we are solving customer engagement problems in the Card and Collections industries so need to operate within those industry level regulatory constraints.
Credit debt is regulated by the FCA with the FCA handbook CONC section 7. Debts outside of the Consumer Credit Act are largely self regulated with industry codes of practice that cover almost all of the major UK lenders and debt collectors. These include the Credit Services Association code of practice, the Finance & Leasing Association lending code, and the Lending Standard Board lending code,
Telecom and Energy providers have their own regulators, such as Ofgem and Ofcom, and give guidance around industry specific debt collection.
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