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Secure Home Systems Ltd fined £80,000 by the ICO

 Article added: 31/10/2018

West Midlands based Secure Home Systems Ltd has been fined £80,000 by the Information Commissioners Office (ICO) for calling consumers registered on the Telephone Preference Service (TPS).

Secure Home Systems provides home security solutions ranging from alarm systems and panic buttons to 24 hour monitoring services.

The company purchased data from third parties with whom it relied upon for their TPS screening.

  1. When you buy data: Whilst it may not be unreasonable to rely on your suppliers’ assertions that any data you purchase has been TPS screened, you should check they have the necessary processes in place such as their own TPS licence or an arrangement with a TPS supplier. In other words, assure yourself they have the necessary tools in place to TPS screen your data in the way they claim.
  2. 28 days later: TPS screening only lasts for 28 days, so if you plan to use any data you’ve purchased after 28 days then you’ll need to have your own TPS screening solutions in place. At that point, it’s no longer on your supplier.

Once purchased, they added new data to their existing database and from then on did not TPS screen their data at all.

Secure Home Systems Ltd - ICO Enforcement Notice

Although, Secure Home Solutions Ltd didn’t screen their data against the TPS, whilst investigating them the ICO also took issue with the fact the business undertook no due diligence on its data suppliers.

Due Diligence

  1. Due diligence on your data suppliers: Although never previously a requirement, for some time now the ICO has expected all businesses purchasing data to undertake some form of due diligence on their data suppliers.
  2. Keep your due diligence safe: Once you’ve done your due diligence, you should keep your records safe in case someone like the ICO asks for them.
  3. Review it regularly: You should conduct at least an annual review of the due diligence on your data suppliers.
secure home systems offices
The offices of Secure Home Systems Ltd

Like many businesses before them, Secure Home Solutions Ltd came to the attention of the ICO due to the number of complaints received about them.

Between 6th Januarys 2016 and 28th February 2018 received 268 complaints (about 20 per month).

These complaints were a little unusual too. Ordinarily, consumer complaints come in the form of being annoyed or being called multiple times and other such common complaints. Instead, the complaints were things like:

“I asked why he was making this call given my TPS membership. He wasn’t bothered. As far as he was concerned, they buy lists in and it’s up to the list supplier to vet TPS issues. Nothing to do with him.”

“Claire claimed to be aware of a spate of burglaries in our area and talked about representatives cleared by the police would be visiting our road shortly. There was a silent system to detect theft, fire etc direct to the services. I said are you working for the police and services or the council/govt or a company. She said she worked for Secured Homes. She denied it was not a sales call. So I said we are on the TPS and why are you calling. She apologised and I hung up. ”

These kinds of “high pressure, answer nothing” telemarketing tactics are old hat nowadays and completely unaccepted by all the regulators.

TPS Services Richard Kane said:

“Anyone undertaking telemarketing expecting to get away with not answering consumer questions about where their data came from is going to struggle.

Also, consumers are more educated about data, their rights and the questions to ask nowadays so claiming that things like TPS screening is nothing to do with you simple won’t wash.

Read the latest ICO Guidance on Direct Marketing. Although it’s 58 pages long, it’s not small print so it’s quite readable. Whether you’ll understand it all or not is another issue, but you should at least try. You can always get answers to the aspects you’re not sure about either directly from the ICO, a compliance company or in some cases by talking to other businesses who also do telemarketing.”

If your business purchases or sells data then you should read the latest Direct Marketing Guidance issued by the ICO for a complete explanation of what the ICO expects from companies involved in or buying from the direct marketing industry.
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