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ODPC Data Protection Act 2019 consent records, withdrawal state, and purpose-level processing controls
Consent ledger read is unavailable. This page is not showing fabricated borrower consent records. Withdrawal queue unavailable; no all-clear claim is shown.
| Processing activity | Lawful basis and data | Launch gate | Evidence | Owner |
|---|---|---|---|---|
Automated credit decisioning and adverse-action reason generation /officer/risk/models / automated-decisioning Review 2026-08-15 | contract necessity, consent, and legitimate interest documented in model governance pack credit bureau data, repayment history, mobile-money signals, business cash-flow features |
| Borrower | Data processing | CRB share | Marketing | Third-party partners | Voluntary KYC | Captured | Channel | Version |
|---|---|---|---|---|---|---|---|---|
| No live borrower consent records are available. Withdrawal queue unavailable; no all-clear claim is shown. | ||||||||
Withdrawal queue unavailable; no all-clear claim is shown. Withdrawal and cease-processing status must come from live consent service rows before operational claims appear here.
The ledger records borrower, consent flags, capture channel, timestamp, and version when live records are available. If the projection is unavailable, processing and withdrawal posture stays unknown instead of presenting an all-clear summary.
Open policy controls| Blocked High-risk processing DPIA required Consultation decision required DPIA approval is required before launch. Data Commissioner consultation decision is required for high-risk processing. Processor contract and subprocessor review must be completed. |
DPIA approved before production model change Data Protection Act, 2019 section 31/35 and NIST AI RMF Govern/Map/Measure/Manage high-risk-dpia-and-consultation-decision Specific adverse-action reasons and data lineage available NIST AI RMF Manage and fair-lending notice controls adverse-action-specific-reasons Human review, override, and contest path are published NIST Privacy Framework Control-P and Communicate-P model-risk-breach-ticket-table |
privacy engineering data protection officer: Watch fair lending: Ready credit risk: Ready |
Purpose-specific consent, withdrawal, and DSAR processing /officer/regulatory/consent / consent Review 2026-09-01 | consent and statutory lending record retention identity, contact details, loan account records, consent purpose history honour withdrawals while preserving loan, dispute, regulator, and money-movement holds | Ready | Purpose-level consent ledger is live-data backed and fail closed Data Protection Act, 2019 and NIST Privacy Framework Govern-P/Control-P consent-ledger-and-dsar-register Withdrawal triggers restriction, redaction, or retention-hold workflow Data Protection Act, 2019 data-subject rights retention-deletion-workflow | privacy office privacy office: Ready privacy operations: Ready |
Credit bureau, collections, telco, and identity processor sharing /officer/admin/op-readiness#operational-resilience / third-party-processing Review 2026-08-31 | contract necessity, consent, and credit risk obligation identity, credit account data, repayment events, collection status processor exports expire by contract schedule; regulator evidence retained for 7 years | Blocked High-risk processing DPIA required Cross-border transfer map DPIA approval is required before launch. Processor contract and subprocessor review must be completed. Cross-border transfer basis and safeguards must be approved. | Processor contracts, subprocessors, breach duties, and exit paths mapped Data Protection Act, 2019 controller/processor obligations third-party-substitutability-table Cross-border transfer basis and recipient safeguards recorded NIST Privacy Framework Identify-P/Protect-P processor-transfer-register | vendor risk vendor risk: Watch privacy office: Watch |
Retention, deletion, restriction, and portability operations /officer/operations/readiness / retention Review 2026-09-15 | data-subject rights balanced against lending, dispute, audit, tax, AML, and regulator evidence holds borrower file, loan ledger, payment events, dispute records, audit events delete or restrict only after hold review, PII inventory pinning, and append-only audit event | Ready | Deletion blocked by loan, dispute, regulator, or money-movement evidence holds NIST Privacy Framework Control-P/Protect-P retention-deletion-workflow PII inventory version pinned before redaction or deletion NIST Privacy Framework Identify-P pii-inventory-version | privacy operations privacy operations: Ready data governance: Ready |