Data Protection Licence

[JR424]

Hello I hope all are well.
I have made 3 SAR requests to DCA who state on all that they are the Data processor and not the controller. This I understand, but my issue is I want the data they are holding not necessarily the creditors data which I have obtained direct. The reason being I am absolutely sure they have used tactics that are against the DCA conduct directives. I have checked that they hold a data protection licence and found three registered at different addresses I have applied to all three but get the same reply.
My understanding of the law is that when acting as the processor it is self explanatory, but if they are holding data across a number of accounts, for 1 person, they are the controller and if that subject wants all of the data then surely they are entitled, am I barking mad or is this correct?

[Amethyst]

I would contact the information commissioners office and tell them what the debt collection company are saying and why you want data from the processor ( ie you believe they are holding different/additional data than provided by the controller )

If we use a processor, does this mean they would have to deal with any subject access requests we receive?

Responsibility for complying with a subject access request lies with you as the controller. You need to ensure that you have contractual arrangements in place to guarantee that subject access requests are dealt with properly, irrespective of whether they are sent to you or to the processor. More information about contracts and liabilities between controllers and processors can be found here.

Is this a consumer credit debt ? If so, when you mention 'dca conduct directives' do you mean the FCA CONC rules/guidance ? ( https://www.handbook.fca.org.uk/hand.../?view=chapter ) That would entail a formal complaint to the firm regarding the breaches and then take the complaint to the Financial Ombudsman.

[JR424]

Yes I could escalate to complaint although I think that the data file will reveal a much deeper seated problem and it might be more prudent to wait.
i shall contact ICO for further advice thank you