The Tribunal found, in support of the ICO, that Experian had not processed the personal data of over 5 million individuals transparently, fairly or lawfully because it failed to notify them that it was processing their data for direct marketing purposes. However, it rejected the ICO’s view that Experian’s privacy notice was not transparent, that using credit reference data for direct marketing purposes was unfair, or that Experian did not properly assess its lawful basis.
