Codes of Conduct

Introduction

FEBIS Members shall conduct this business lawfully and comply with all relevant legislation and judicial decisions. The shall trade fairly and responsibly and behave at all time with integrity towards both its clients and debtors. FEBIS members will provide adequate training for its staff, bringing to their attention the principles of these Codes and requiring them to carry out their duties in full accordance with these principles

Principles

FEBIS members are business information agencies. As such we are neutral suppliers of information. We support the financial, economic and commercial decisions made by industry, insurance, trade and commerce, credit businesses etc. about companies and other businesses. (Some FEBIS members supply information on private individuals).

We promote the industry by providing information for business decisions.

We recognise the importance of our activities with regard to the basic rights of the data subject concerned on informational self-determination. We collect and use such data fairly and lawfully in accordance with the relevant data protection laws.

In particular we take all reasonable steps to ensure that such data is accurate and, where necessary, kept up-to-date. Business information should be updated according to the circumstances of each case in order to give a true and correct picture of the subject business by reference – where appropriate – to a stated date.

We shall therefore

    take account of any overriding interests of the data subject and the interests of the data recipient
    respect the confidentiality of sources providing data
    take appropriate measures to protect personal data against unauthorised alteration, disclosure or access and against unlawful forms of use
    respect the principle of transparency in our activities

correct, suppress or delete incorrect or irrelevant data at the request of the concerned party (after completing all the necessary double-checking to ensure the accuracy of the changes asked) or independently when inaccuracy or irrelevance is noticed.

Some FEBIS Members operate a debt collection service and as such comply fully with the Code of Conduct of FEBIS. The objective of this code is to achieve a high level of proficiency, lawful service together with professional reputation and standards. FEBIS appoints a Compliance Committee to investigate any breach of compliance by its Members. Any debtor, creditor, third party or FEBIS Members shall be entitled to complain in writing to the Compliance Committee about a breach of the Code of Conduct.

Balance of interests

We are obliged to balance the interests of the data subject against the interests of a data recipient by taking into consideration the degree of relevance of the data to a business decision; i.e. the more commercially active a person, the stronger the legitimate interests of the data recipient.

Data Collection

We collect data by using generally accessible and public sources (i.e. public registers, published balance-sheets, official gazettes, newspapers) and by written or oral questioning of the data subject. Questioning of relevant third parties may take place to confirm or complete the information held and any data obtained in this way is cross-checked to ensure its reliability. Where such third parties provide data on a confidential basis, we shall respect this confidentiality.

Transparency of the Activities

In different countries transparency of data use is ensured under local laws either by pro-active or re-active requirements. These may include the obligation to inform data subjects of the storage of their data and to make it possible for them to obtain information about its type, extent and main purpose of use.

Data Security

We shall implement appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, accidental loss, unauthorised alteration, disclosure or access and all other unlawful forms of processing. Such measures shall ensure a level of security appropriate to the risks represented by the processing and the nature of the data to be protected. We shall ensure that our employees understand their obligation to maintain the security and confidentiality of data and that they accept appropriate confidentiality measures.

Data Compliance Officer

We shall implement appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, accidental loss, unauthorised alteration, disclosure or access and all other unlawful forms of processing. Such measures shall ensure a level of security appropriate to the risks represented by the processing and the nature of the data to be protected. We shall ensure that our employees understand their obligation to maintain the security and confidentiality of data and that they accept appropriate confidentiality measures.

Compliance Committee

FEBIS has appointed a compliance committee to ensure compliance by its members with this code of conduct. Any data subject, data recipient of FEBIS member shall be entitled to complain in writing to the compliance committee about a breach of this code of conduct.

The committee shall give its written opinion about the complaint within 2 months of receiving the complaint. The committee shall have power to take appropriate actions against any FEBIS member whom it decides has breached this code of conduct. Such action may include formal reprimand or exclusion from FEBIS.