1. Introduction 1.1 About this report This report focuses on the Commissioner’s investigation into the offline marketing services of the data broking industry and, in particular, the activities of the UK’s three largest credit reference agencies (CRAs) within this industry; Experian Limited, Equifax Limited, and the relevant entities within the TransUnion group of companies (TransUnion International UK Limited and Callcredit Marketing Limited). It is important to note that this investigation has focused on the CRAs’ data broking for direct marketing activities, and not their core credit referencing function. ‘Offline’ marketing services, as referred to in this report, focus on providing marketing to individuals through methods other than the internet. This can include postal, telephone and SMS marketing. It also means that the focus of the profiling activities we investigated and address in this report does not include data collected about an individual’s online behaviours. We are investigating participants in the online advertising industry separately. This report provides background information on the law and our investigation, discusses the key findings, outlines the action we have taken, provides conclusions, and outlines next steps. As well as this report we have also published the executive summaries of the audits undertaken and the enforcement notice issued by the Commissioner. This report is concerned with the thematic issues; the audit executive summaries provide information about the specific processing of each CRA.
1.2 What is data broking for direct marketing purposes? The ICO has adopted the following definition of data broking for direct marketing purposes, based on our knowledge of the industry:
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