Lloyds seem to have different standards to be satisfied that I am me. They refuse to comply with my recent subject access request unless I provide additional proof of identity.
I have lived at the same address, and had accounts with Lloyds for many years. My name is unchanged since birth.
I have used a digital printed signature since last summer. Lloyds complied with a S78 request without query, they write to me in response to my letters discussing personal information and continue to send statements and other sensitive personal info.
I spoke to the Information Commissioner's Office - they say that Lloyds are being inconsistent and I should challenge them about it.
Here is the exchange of letters. I would be grateful for caggers advice.
1. My Subject Access Request using the CAG template and £10 postal order. Signed digitally.
2. Reply from Lloyds -
We see that we do not hold an up to date signature for you. For your security we will require a copy of either your Passport or Driving Licence, certified by a Lloyds TSB branch for identification purposes. Please call in to your local branch with these documents and they will be happy to update your signature on our records.
Alternatively, once we have collected the information you can personally collect the parcel from a branch of your choice. You will be required to show some form of identification, such as your Passport or Driving Licence. If we do not hear from you within one month we will close our file. We will reopen it if you come back to us at any point afterwards.
3. My reply (extracts) -
I have been using my digital signature to correspond with you for several months.
You have continued to send extensive sensitive private information and correspond with me, why haven't you queried my identity before now?
I do not wish to collect the data from a branch, please send it to me.
In order to allay your concerns I enclose a copy of a recent utility bill addressed to me here as further verification of my identity.
4. LLoyds response -
In order to protect your personal information and prevent it getting into the wrong hands we do require confirmation of your identity.
I appreciate that we do regularly send other personal information to your address, however in this instance there could be a large volume of your personal information, including a full set of statements for several accounts over several years. It is therefore imperative that this information does not go astray and is only made available to the person entitled to the data.
Therefore, in order to comply with your request, would you please either sign the attached authorisation form or indicate which branch would be the most convenient for you to collect from.
In our experience the Information Commissioner's Office are supportive of such measures, which prevent possible breaches of the Data Protection Act 1998.
Yours sincerly
Lloyds TSB
Data Subject Access Requests