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DWP Social Loan(s) Claim & Possible Breach of Data Protection and ECHR

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  • DWP Social Loan(s) Claim & Possible Breach of Data Protection and ECHR

    Hi Guys

    Those of you that know me well, know i first started my first company back in April 2009 and prior to that and until the company started to become successful i was claiming JSA (though declared any income and signed off, once income was steady). Anyway since April 2012 i have been getting demands for repayment of a social fund of £158.32 - Now i have no recollection of ever having such a loan, in fact my last social loan was probably between 2005 and first half of 2008 and was less than £40. I have never in all my time whilst i was on benefits (on and off) between the year 2000 and 2009 had any social loan over £90 that i can recall.

    Anyway, today i just received another letter in the post from DWP claiming a separate amount for social fund of £98.32 and exact difference of £60.00 to the earlier amount claimed. Not only that the letter was in an unsealed and opened envelope, meaning anyone with access to the letter between it being printed and originally placed in the envelope and it being delivered by royal mail this morning could have easily have taken out the letter, read it and placed it back in the envelope, and i'd be non the wiser. So does this amount to breach of the Data Protection Act 1998 and article 8 ECHR Right to privacy - Reference law protection confidential information (Financial and NI number)? Answer in my opinion is yes it does, as its a clear act of negligence on the part of DWP that had left my confidential information open to be abused/stolen and my details and details of the alleged debt to them being accessible by 3rd parties.

    Here is my letter i wrote in response to them - I shall post up the photo's tomorrow if i get the time to do so.

    Dear Robert Smith

    Thank you for your letter dated 10th February 2014, received today 14th February 2014 via the royal mail, in an unsealed and opened enveloped. Which shows evidence of not being sealed at all prior to dispatch, given there is no tear damage on the back of the envelope from the seal being opened and the fact the glue on the lip of the envelope is still new and unused – Though there is minor sign of dampness on the back of the envelope where the seal would stick to the back of the envelope. Which is evidence that there was not an efficient amount of liquid/saliva applied to the seal prior to sealing the envelope, it is also evidence that the seal was not sufficiently checked to ensure it was sealed, or the downright “I can’t be bothered to correct” attitude, prior to posting. Yes I have photographic evidence of this, as well as the envelope in question with comparison photos of the return envelope that was also included with your letter - Copies of the Photos can be supplied on request – but I shall keep the original envelopes.

    Such negligence means that anyone who had access to the letter prior to it being delivered to me, could have taken the letter out of the envelope and read it, before placing it back in the envelope. This is a serious breach of Data Protection Act 1998. Also as you are a public authority, you are therefore may also be in breach of my right to privacy under the Article 8 of the European Convention of Human Rights – Reference law on Protection of Confidential Information (Financial and NI Number). I shall be seeking legal advice on this breach to my rights and data protection and will consider making a formal complaint to the information commissioner’s office and the minister in charge of your department should I not receive a satisfactory settlement offer.

    Now as for the content of your letter; you alleged that I owe a debt towards a social fund (I assume loan) of £98.32 – I dispute this, as you provide no evidence to support your claim, such as a breakdown of date(s) the loan was taken out on, or for repayments and sums made in repayments. Not only that I have been receiving letters from your Debt Management department from since early 2012 for an amount of £158.32 exactly £60 more, which is also an alleged Social Fund Loan, which is also disputed and again no evidence was supplied to support such claim.

    On top of that, you are claiming what appears to be a second loan, which is exactly £60 less than the one originally claimed. How is it likely to have two social fund loans at the same time where the difference is exactly £60? In fact I always thought you were only entitled to one social fund loan at a time and could not apply for another one if you had a previous one outstanding! Not only that, I have no recollection of taking a loan for either the amounts being claimed, my last recollection from taking or applying for a social loan was an offer of less than £40. In fact, I have never had more than £90 in total on any social loan I had applied for in the past 10 years where i was on job seekers, and all were repaid, to the best of my knowledge, by deductions to JSA payments at the time.

    I therefore dispute and do not acknowledge either claims to either sums, and I remind you that in law the onus of prove is on your to provide prove (evidence) to support your claim. So far no such prove has been provided by me, and you are merely, in my view sending me nothing but speculative invoices making demands for money that you have not even proven to be owed by myself. If the evidence is supplied and it proves beyond reasonable doubt to me that I may owe said sums, then I will off course arrange repayments, but so far, all I have is just your say so and nothing for me to go on that would enable me to check my own records to validate your claims. Basically your sending letters say I owe XYZ amount to you, without you providing evidence to support your claim - Is like me saying to my friend that he still owes me £100 that I lent him a few years back, to which he no longer has any recollection of borrowing from me and to which I have no evidence to prove I did lend it to him.

    Yours Sincerely


    Teaboy2
    Let me know what you guys think about this - bear in mind, as i said, i have not been on JSA since 2009 and have not had any social loans since 2008 at the latest, and non where in the ranges of what they are claiming because as far as i am aware they were all paid back as per originally agreed when i applied.

    EDIT ----

    Here are the images of the Envelope as it were when it was received (I have left 3 images out as they contain my details etc):

    You can clearly see that the seal is still intact, and there are no tears as would be expected from opening a sealed envelope, and the glue on the lip is still new and unused, though you can see dampness on the back of the envelope that indicates some attempt, but insufficient, was used to seal it.
    Attached Files
    Last edited by teaboy2; 15th February 2014, 15:39:PM.
    Please note that this advice is given informally, without liability and without prejudice. Always seek the advice of an insured qualified professional. All my legal and nonlegal knowledge comes from either here (LB),my own personal research and experience and/or as the result of necessity as an Employer and Businessman.

    By using my advice in any form, you agreed to waive all rights to hold myself or any persons representing myself of any liability.

    If you PM me, make sure to include a link to your thread as I don't give out advice in private. All PMs that are sent in missuse (including but not limited to phishing, spam) of the PM application and/or PMs that are threatening or abusive will be reported to the Site Team and if necessary to the police and/or relevant Authority.

    I AM SO GOING TO GET BANNED BY CEL FOR POSTING terrible humour POSTS.

    The Governess; 6th March 2012 GRRRRRR
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  • #2
    Re: DWP Social Loan(s) Claim & Possible Breach of Data Protection and ECHR

    This may sound obvious but have you considered sending the DWP a SAR?

    Comment


    • #3
      Re: DWP Social Loan(s) Claim & Possible Breach of Data Protection and ECHR

      Originally posted by FlamingParrot View Post
      This may sound obvious but have you considered sending the DWP a SAR?
      Yes, but my view is that they should provide prove without myself having to do a SAR at my expense, since its they that are claiming i owe XYZ. All they need to do is provide details as to dates and amounts so i can then check my bank accounts, but they have failed to do so after a number of requests - And it is a perfectly reasonable request to ask for such prove. And i don't see why i should spend hours going through my bank statements form as far back as the year 2000, if they can not be bothered to provide such basic information that would allow me to look up the dates precisely within a few minutes. Hence why i requested proof again in the letter i posted at the start of the thread.

      Besides my main concern here is not what they are claiming, but the fact my data and NI number could have fallen into the wrong hands or could now be known to 3rd parties as a result of their negligence. Anyone could now use that to falsely claim benefits or use it to steal my ID for use with applying for other things etc. Yes i know its unlikely, but that's not the point as its now a possibility that should not even be a possibility. All because of them not sealing the envelope, and it only takes one dishonest/desperate individual that had access to the letter during its transit to my letter box, to take advantage of knowing/having my NI number.
      Last edited by teaboy2; 15th February 2014, 15:42:PM.
      Please note that this advice is given informally, without liability and without prejudice. Always seek the advice of an insured qualified professional. All my legal and nonlegal knowledge comes from either here (LB),my own personal research and experience and/or as the result of necessity as an Employer and Businessman.

      By using my advice in any form, you agreed to waive all rights to hold myself or any persons representing myself of any liability.

      If you PM me, make sure to include a link to your thread as I don't give out advice in private. All PMs that are sent in missuse (including but not limited to phishing, spam) of the PM application and/or PMs that are threatening or abusive will be reported to the Site Team and if necessary to the police and/or relevant Authority.

      I AM SO GOING TO GET BANNED BY CEL FOR POSTING terrible humour POSTS.

      The Governess; 6th March 2012 GRRRRRR

      Comment


      • #4
        Re: DWP Social Loan(s) Claim & Possible Breach of Data Protection and ECHR

        Failure to adequately secure data is a de facto breach of the Act. That said, it is highly unlikely that a complaint would get anywhere.

        With regard to proof of their claim, I suspect that the DWP will prove uncooperative, and will probably refer the matter directly to their hired goons. In the meantime, build a paper trail demonstrating that they have behaved unreasonably.

        Comment


        • #5
          Re: DWP Social Loan(s) Claim & Possible Breach of Data Protection and ECHR

          Totally agree...shocking way to send snail mail .

          DWP have decided to have a clean up and are scrolling back 20-30 years to try and get monies that are allegedly owed,,but in a lot of cases NOT owed.
          I had a request for over 2k of WTC,,,which is fine,,wrong,,but fine,,didn't mind them asking for it cos they won;t be getting it because when they claim it's owed from is a crock of crap,,,,,,,,I couldn't walk and could barely see at that time so God knows how I'm meant to have worked,,,cooked via braille perhaps? (was a chef,back in the day)...
          They're being a pain in the posterior Teaboy,,treat them with the contempt they deserve.

          Comment


          • #6
            Re: DWP Social Loan(s) Claim & Possible Breach of Data Protection and ECHR

            Hi Teaboy,

            The envelope is what is known as a machine envelope, meaning it is for use with automated post room machinery that folds and inserts letters into envelopes before sealing the envelope. What has happened in your case can happen with such machinery, but it is a rare occurrence. Notwithstanding, you are absolutely right to kick up about this. Certainly, the ICO should be involved as your NI Number is unique to you and could be used by a person with ill-intent to commit identity theft.

            As to the Human Rights Act 1998, I am not convinced that you have a case under Article 8, but the demands DWP are making are subject to Article 6. If you experience any further problems with DWP, speak to your MP about pursuing the matter with the Parliamentary Ombudsman as there may be issues of maladministration on the part of DWP.
            Life is a journey on which we all travel, sometimes together, but never alone.

            Comment


            • #7
              Re: DWP Social Loan(s) Claim & Possible Breach of Data Protection and ECHR

              Originally posted by enquirer View Post
              Failure to adequately secure data is a de facto breach of the Act. That said, it is highly unlikely that a complaint would get anywhere.

              With regard to proof of their claim, I suspect that the DWP will prove uncooperative, and will probably refer the matter directly to their hired goons. In the meantime, build a paper trail demonstrating that they have behaved unreasonably.
              Am not to sure that they will rest on there morals regarding breach of data protection etc, after all they are a public body and i doubt the ICO would want to be seen as biased when dealing with other government departments breaches of data protection either, to be honest. Yes they will probably deny wrong doing, but the evidence (photos) proves otherwise. As fro their hired goons, well almost 2 years down the line and they still repeat themselves in each letter and its got them no nearer to getting a penny of me yet lol.

              Originally posted by Inca View Post
              Totally agree...shocking way to send snail mail .

              DWP have decided to have a clean up and are scrolling back 20-30 years to try and get monies that are allegedly owed,,but in a lot of cases NOT owed.
              I had a request for over 2k of WTC,,,which is fine,,wrong,,but fine,,didn't mind them asking for it cos they won;t be getting it because when they claim it's owed from is a crock of crap,,,,,,,,I couldn't walk and could barely see at that time so God knows how I'm meant to have worked,,,cooked via braille perhaps? (was a chef,back in the day)...
              They're being a pain in the posterior Teaboy,,treat them with the contempt they deserve.
              Don't you worry Inca, they have angered the wrong person here so i will not be letting up on this one - Especially when my NI number could now be in, or have fallen into, the hands of a 3rd party, putting my identity at risk of being used for fraud, and other criminal actions.

              Originally posted by bluebottle View Post
              Hi Teaboy,

              The envelope is what is known as a machine envelope, meaning it is for use with automated post room machinery that folds and inserts letters into envelopes before sealing the envelope. What has happened in your case can happen with such machinery, but it is a rare occurrence. Notwithstanding, you are absolutely right to kick up about this. Certainly, the ICO should be involved as your NI Number is unique to you and could be used by a person with ill-intent to commit identity theft.

              As to the Human Rights Act 1998, I am not convinced that you have a case under Article 8, but the demands DWP are making are subject to Article 6. If you experience any further problems with DWP, speak to your MP about pursuing the matter with the Parliamentary Ombudsman as there may be issues of maladministration on the part of DWP.
              Used to work with similar machinery my friend, and it should be supervised by a human operator even if it is automated. So there is no excuse for it happening. Its likely the part of the machine that lubricates the envelopes lip did not have enough lubricant or had run out or was running low resulting in the lip being folded but not sealed as it passed through the machine, or the part that seals it was either bent or not applying enough pressure, due to other reasons, to allow the seal to form. So its probably happened to a load of other envelopes at the same time. Hell, it could have just been a jam in the machinery leading to some envelopes being removed and simply placed on to the next section of the line, without being adequately checked to ensure they were all sealed properly.

              I will have a look at article 6 but i believe it may apply to both article 6 and 8 in regards to protection of confidential information. Will also consider speaking to Anne Mackintosh, shes only 10 minutes walk away from me lol.

              By the way, i haven't as yet posted the letter, but i will be doing so tomorrow. So if anyone has anything they thing i should add of change, then please let me know.
              Please note that this advice is given informally, without liability and without prejudice. Always seek the advice of an insured qualified professional. All my legal and nonlegal knowledge comes from either here (LB),my own personal research and experience and/or as the result of necessity as an Employer and Businessman.

              By using my advice in any form, you agreed to waive all rights to hold myself or any persons representing myself of any liability.

              If you PM me, make sure to include a link to your thread as I don't give out advice in private. All PMs that are sent in missuse (including but not limited to phishing, spam) of the PM application and/or PMs that are threatening or abusive will be reported to the Site Team and if necessary to the police and/or relevant Authority.

              I AM SO GOING TO GET BANNED BY CEL FOR POSTING terrible humour POSTS.

              The Governess; 6th March 2012 GRRRRRR

              Comment


              • #8
                Re: DWP Social Loan(s) Claim & Possible Breach of Data Protection and ECHR

                Isn't the bigger issue that there's a social fund loan being charged to you that you have no knowledge of?
                #staysafestayhome

                Any support I provide is offered without liability, if you are unsure please seek professional legal guidance.

                Received a Court Claim? Read >>>>> First Steps

                Comment


                • #9
                  Re: DWP Social Loan(s) Claim & Possible Breach of Data Protection and ECHR

                  Originally posted by Amethyst View Post
                  Isn't the bigger issue that there's a social fund loan being charged to you that you have no knowledge of?
                  That's where Article 6 of ECHR comes in, Amethyst. DWP are bound by it. Section 6, Human Rights Act 1998 makes it unlawful for any public authority to perform any act that is incompatible with a person's Convention rights. The politicians and civil serpents tend to overlook ECHR and the HRA and regard them as an inconvenience and an irritation. Each year, on average, the UK is before the European Court of Human Rights for breaches of ECHR. Also, it would appear that Canada and The Netherlands have been voicing concerns over human rights violations by the UK government.

                  Teaboy, as far as I am aware, Article 8 of ECHR is more to do with interference with and interception of mail and communications by the State. TBH, I feel you would probably do better addressing the insecure envelope via ICO. Somehow, I think they would relish taking DWP's scalp. However, in IDS's case, they may have a job taking his scalp as he has next to no hair left to remove.
                  Life is a journey on which we all travel, sometimes together, but never alone.

                  Comment


                  • #10
                    Re: DWP Social Loan(s) Claim & Possible Breach of Data Protection and ECHR

                    Originally posted by Amethyst View Post
                    Isn't the bigger issue that there's a social fund loan being charged to you that you have no knowledge of?
                    Not really, i have asked them numerous times to send proof on the one they originally claimed, and have again asked for prove in the above letter. If they don't supply such proof, then i won't respond until they send another letter demanding payment, like it has always been in the past. Its been like that since April 2012.

                    I doubt they will take it much further, as i have history with the DWP and they were in the wrong those times too - One such instance was when i was declaring my income, i handed in copies of sales invoices and purchases orders for those sales, along with profit slip for profit from those sales. There decision maker ignored the purchase orders and profit slip and took my income as being equal to the amounts on the sales invoices - In response, i did a spread sheet for the same invoices and purchase orders, showing the difference between purchase price and sales prices (excluding VAT by the way) which worked out as exactly what i had put on my profit slip. I also included a note explaining that total sums of sales is not net profit, net profit is sums of sales for the period minus sums of purchase orders for the same period both sums excluding VAT for those registered, or including VAT for those that are not registered. And i said at the end of the note "Its not bloody rocket science.. is it?!! - Cheeky i know, but it showed the incompetence of the DWP staff and lack of intelligent thought they had shown. Their decision meant that i did not get the benefits for that period to which i was actually entitled too at the time, until it was back dated to me a month later. Hell i even got threatened with sanctions for not looking for work when i had started my own business.

                    There was a number of other disputes i had with them too, one being when i applied to sign on and was told the reason i gave for leaving my previous job (not the job i had just left, which was agency work) 3 years before hand, was no longer satisfactory so i was not entitled to job seekers. That was despite my reason for leaving that job 3 years beforehand being satisfactory at the time. Soon got that sorted out too. Note: between 2000 - 2009 i had had various forms of employment and done various jobs, some fixed term some full time and some agency.

                    So yeah my main concern now is the risk to identity theft they have placed me under as a result of them sending an letter containing my details and NI number in and open and unsealed envelope, and not what they are claiming i owe. Because until they can prove i owe it, which i do not believe that i do, then they got more chance of hell freezing over.
                    Please note that this advice is given informally, without liability and without prejudice. Always seek the advice of an insured qualified professional. All my legal and nonlegal knowledge comes from either here (LB),my own personal research and experience and/or as the result of necessity as an Employer and Businessman.

                    By using my advice in any form, you agreed to waive all rights to hold myself or any persons representing myself of any liability.

                    If you PM me, make sure to include a link to your thread as I don't give out advice in private. All PMs that are sent in missuse (including but not limited to phishing, spam) of the PM application and/or PMs that are threatening or abusive will be reported to the Site Team and if necessary to the police and/or relevant Authority.

                    I AM SO GOING TO GET BANNED BY CEL FOR POSTING terrible humour POSTS.

                    The Governess; 6th March 2012 GRRRRRR

                    Comment


                    • #11
                      Re: DWP Social Loan(s) Claim & Possible Breach of Data Protection and ECHR

                      Yes ok. But is there a loan that is being charged to you that you did not take out ?

                      Sorry crossed posts, so Yes there is.
                      #staysafestayhome

                      Any support I provide is offered without liability, if you are unsure please seek professional legal guidance.

                      Received a Court Claim? Read >>>>> First Steps

                      Comment


                      • #12
                        Re: DWP Social Loan(s) Claim & Possible Breach of Data Protection and ECHR

                        Originally posted by bluebottle View Post
                        That's where Article 6 of ECHR comes in, Amethyst. DWP are bound by it. Section 6, Human Rights Act 1998 makes it unlawful for any public authority to perform any act that is incompatible with a person's Convention rights. The politicians and civil serpents tend to overlook ECHR and the HRA and regard them as an inconvenience and an irritation. Each year, on average, the UK is before the European Court of Human Rights for breaches of ECHR. Also, it would appear that Canada and The Netherlands have been voicing concerns over human rights violations by the UK government.

                        Teaboy, as far as I am aware, Article 8 of ECHR is more to do with interference with and interception of mail and communications by the State. TBH, I feel you would probably do better addressing the insecure envelope via ICO. Somehow, I think they would relish taking DWP's scalp. However, in IDS's case, they may have a job taking his scalp as he has next to no hair left to remove.
                        Well ECHR would be a last resort in any case, but putting the threat there in their faces was more a tactical move, than anything else. I.e. let them know that you know that they could end up in the shit for it big time.

                        Am not to certain about the ICO relishing the chance to scalp the DWP, they are both government bodies. Although the ICO is a non department body it still reports directly to parliament. And i doubt Cameron and co would want them embarrassing IDS and the conservatives as a result of such an investigation. So i can see some behind the scenes interference taking place, should the ICO take it on. Though off course that will not stop me from making a complaint as it would only strengthen my standing should i end up having to take the matter to court.

                        Originally posted by Amethyst View Post
                        Yes ok. But is there a loan that is being charged to you that you did not take out ?

                        Sorry crossed posts, so Yes there is.
                        Yes they are claiming 2 one for £158.32 they started claiming back in April 2012 and the new one is for £98.32 - No idea when the alleged loans originated from. Because as i said, they won't provide the proof i have asked for many times.

                        Neither appears on my credit file so its not real concern to me, as they can claim as much as they want. They won't get anything till they provide me the proof i have asked for, where i can then use the dates contained within to check my bank accounts to confirm if i had or had not received such loans. And even if i had taken the loans, the repayments would have been made by deductions to benefits at the time. So i also need to know what repayments towards such alleged loans were to calculate whether what they are claiming is accurate amounts or whether they are claiming the total loan amounts without consideration from previous repayments.

                        I do not dispute having social loans between 2000 and 2009 i had a number of them during that period. But i dispute the amounts/loans they are claiming as i never, from what i can recall, had any loan of more than £90 and all were to the best of my knowledge repaid by deductions to my benefits at the time.
                        Please note that this advice is given informally, without liability and without prejudice. Always seek the advice of an insured qualified professional. All my legal and nonlegal knowledge comes from either here (LB),my own personal research and experience and/or as the result of necessity as an Employer and Businessman.

                        By using my advice in any form, you agreed to waive all rights to hold myself or any persons representing myself of any liability.

                        If you PM me, make sure to include a link to your thread as I don't give out advice in private. All PMs that are sent in missuse (including but not limited to phishing, spam) of the PM application and/or PMs that are threatening or abusive will be reported to the Site Team and if necessary to the police and/or relevant Authority.

                        I AM SO GOING TO GET BANNED BY CEL FOR POSTING terrible humour POSTS.

                        The Governess; 6th March 2012 GRRRRRR

                        Comment


                        • #13
                          Re: DWP Social Loan(s) Claim & Possible Breach of Data Protection and ECHR

                          You are right that ECHR is a last resort, TB. It is my understanding that you need to exhaust all other avenues of resolution before resorting to action under ECHR. Within the Civil Service, there does tend to be rivalry between the different government agencies and departments. A lot of people, including civil servants, do not agree with the way in which DWP is treating benefit claimants and I would not be in the least bit surprised if ICO took a pop at DWP just to give IDS something to whinge about and embarrass him. The fines ICO hands out are Civil Monetary Penalties and do not go through the courts. I bet you, though, that Cameron would try his best to keep any fine from the public, the disingenuous little so-and-so.
                          Life is a journey on which we all travel, sometimes together, but never alone.

                          Comment


                          • #14
                            Re: DWP Social Loan(s) Claim & Possible Breach of Data Protection and ECHR

                            Originally posted by bluebottle View Post
                            You are right that ECHR is a last resort, TB. It is my understanding that you need to exhaust all other avenues of resolution before resorting to action under ECHR. Within the Civil Service, there does tend to be rivalry between the different government agencies and departments. A lot of people, including civil servants, do not agree with the way in which DWP is treating benefit claimants and I would not be in the least bit surprised if ICO took a pop at DWP just to give IDS something to whinge about and embarrass him. The fines ICO hands out are Civil Monetary Penalties and do not go through the courts. I bet you, though, that Cameron would try his best to keep any fine from the public, the disingenuous little so-and-so.
                            Agreed, and yes Cameron might try to push it under the carpet, but i won't. The press is only a phone call away, after all! lol
                            Please note that this advice is given informally, without liability and without prejudice. Always seek the advice of an insured qualified professional. All my legal and nonlegal knowledge comes from either here (LB),my own personal research and experience and/or as the result of necessity as an Employer and Businessman.

                            By using my advice in any form, you agreed to waive all rights to hold myself or any persons representing myself of any liability.

                            If you PM me, make sure to include a link to your thread as I don't give out advice in private. All PMs that are sent in missuse (including but not limited to phishing, spam) of the PM application and/or PMs that are threatening or abusive will be reported to the Site Team and if necessary to the police and/or relevant Authority.

                            I AM SO GOING TO GET BANNED BY CEL FOR POSTING terrible humour POSTS.

                            The Governess; 6th March 2012 GRRRRRR

                            Comment


                            • #15
                              Re: DWP Social Loan(s) Claim & Possible Breach of Data Protection and ECHR

                              Its obvious to any postman or anybody who has a brown envelope in their hands that reading the address on the back of the envelope that its a government department letter.
                              If they were so inclined they could open a letter and obtain the info inside which in DWP mail may include a NI number easypeasy. So would the department be guilty of breaching data protection?

                              Same applies with letters from a DCA the return postcode tells all

                              Comment

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