The Information Commissioner’s Office (ICO) has fined Bounty (UK) Limited £400,000 for illegally sharing personal information belonging to more than 14 million people. An ICO investigation found that Bounty, a pregnancy and parenting club, collected personal information for the purpose of membership registration through its website and mobile app, merchandise pack claim cards and directly from new mothers at hospital bedsides.
But the company also operated as a data broking service until 30 April 2018, supplying data to third parties for the purpose of electronic direct marketing. Bounty breached the Data Protection Act 1998 by sharing personal information with a number of organisations without being fully clear with people that it might do so. The company shared approximately 34.4 million records between June 2017 and April 2018 with credit reference and marketing agencies, including Acxiom, Equifax, Indicia and Sky. These organisations represented the four largest recipients out of a total of 39 organisations which Bounty confirmed it shared personal data with.
Number of used miss-used data unprecedented
The personal information shared was not only of potentially vulnerable, new mothers or mothers-to-be but also of very young children, including the birth date and sex of a child. Steve Eckersley, ICO’s Director of Investigations, said: “The number of personal records and people affected in this case is unprecedented in the history of the ICO’s investigations into data broking industry and organisations linked to this.
Not open or transparent
“Bounty were not open or transparent to the millions of people that their personal data may be passed on to such large number of organisations. Any consent given by these people was clearly not informed. Bounty’s actions appear to have been motivated by financial gain, given that data sharing was an integral part of their business model at the time. “Such careless data sharing is likely to have caused distress to many people, since they did not know that their personal information was being shared multiple times with so many organisations, including information about their pregnancy status and their children”
The investigation found that for online registrations, Bounty’s privacy notices had a reasonably clear description of the organisations they might share information with, but none of the four largest recipients were listed. Additionally, none of the merchandise pack claim cards and offline registration methods had an opt-in for marketing purposes.