GreenSquareAccord and the curse of missing data!

Another ongoing issue is GreenSquareAccord’s inability or unwillingness to maintain accurate record keeping. Why is it so hard for GreenSquareAccord to keep their records updated, to keep hold of calls and emails, or is it simply a case of them being better off when these customer communications are lost?

Old issues?

…your complaint has highlighted that there are clear communication, ownership and record keeping issues between internal departments once your initial contact has taken place which makes it difficult for the Customer Service Team to help you or other residents when you contact us.

Gemma Freegard (GreenSquare Customer Care Specialist)

25th September 2020

I’m not going to go through this chapter and verse as I can link to other examples much easier; for those wanting more examples of GreenSquareAccord and their inability to manage and track data you can read here, here, here, and (for the dedicated) here, and lest we forget here and here!

The issue of record keeping had not been remedied over a year later:

Please can you give me a little more time as I haven’t been forwarded your email yet despite my team scanning for new emails every day. You will know we have received some as we have responded to some repair requests you have submitted. 

I asked our IT team last week to check the routing as I was expecting an email from you but hadn’t received it yet. I will chase them now for an outcome and be in touch again by Wednesday.

Julianne Britton (GreenSquareAccord Director of Customer Services)

1st November 2021

So, an ongoing issue I think we can all agree.

But is it an ongoing issue or a rather convenient excuse?

Convenient excuse?

Surely not? I know it sounds so far fetched. Perhaps I have gone too far down the rabbit hole. However GreenSquareAccord’s inability to manage, maintain, and track data being an excuse stacks up.

3rd May 2022 - In response to a GreenSquareAccord letter on the 21st April I issued GreenSquareAccord with a Subject Access Request. This gave GreenSquareAccord a month to respond, however they would require longer to compile this information as:

On 30 May 2022, at 15:41, Data Protection <Data.Protection@greensquareaccord.co.uk> wrote:

Hello, 

I am writing to let you know that it is necessary to extend the deadline connected to your Subject Access Request. The Data Protection Legislation provides for an extension of up to two months to the standard one month. 
 
It is necessary in the case of your Subject Access Request that the Data Controller extends the response time by one month only, and the new response date is 03/07/2022

It is necessary to extend the response date as there is complexity with your information and technical difficulties in retrieving information sets. Of course, once the disclosure is ready, it will be served to you. 

Your Sincerely 
 
The Data Protection Team @ GreenSquareAccord 
data.protection@greensquareaccord.co.uk 

Why would they need an extension I wondered, so I asked:

From: ***********
Sent: 30 May 2022 18:53:58
To: "Data Protection" <Data.Protection@greensquareaccord.co.uk>
CC: "Merged Mailbox" <info@greensquareaccord.co.uk>
Subject: Re: IR22/23/02-020 Extension Applied

Hello,

Thank you for your email.

Can  you please summaries exactly what complexities and technical difficulties you are facing in retrieving my information sets?

Dear CS team - can you forward this email onto the data protection inbox as my email maybe blocked?

Regards

Ben ******

To which they replied:

Hello 

Thank you for your email.

As you are aware we are in the process of merging into GreenSquareAccord and so different service teams are changing. Due to request, and the many areas of the business this relates to.

We are experiencing issues due to:

Technical difficulties in retrieving the information.

Your request involves large volumes of information.

It is important to us that you receive your information as lawfully entitled so are working hard to complete this. Please note that if we do not need to utilise the full extension period we will not, disclosing to you as soon as possible.

Regards

Data Protection Team

W greensquareaccord.co.uk

Let’s call out some of the nonsense in this response shall we? To start surely GreenSquareAccord have backed up all data before merging two systems? Assuming they have, all of my historic data would be held within this siloed data set, which would be stored in a standalone system - surely?

Point two - I’m on a communication ban and GreenSquareAccord have already made reference to these communications while considering (it was a foregone conclusion and not considered) the extension to my communication ban!

Why is not in their interest to do so?

What is the fallout if they don’t comply? Well we can report them to the ICO, but as we’ve already seen this isn’t something GreenSquareAccord fear. Non-compliance is more likely to be less damning to their corporate brand and image than the requested information being shared.

The results for complaining to the ICO seems to be marginal. Here is how the ICO responded to a complaint regarding the lack of response to a Subject Access from another GreenSquareAccord resident. [With thanks and love to our fellow resident - stay strong x]

Response from ICO dated 8th June 2022

Your complaint

You have written to us because you submitted a subject access request (SAR) to the organisation and did not receive an appropriate response.

Our view

I have raised the case of your SAR with the organisation and have considered the information available in relation to this complaint and I am of the view that Green Square Accord has not complied with their data protection obligations. This is because you did not receive an appropriate response to your SAR.

When we raised your complaint with the organisation they have admitted responsibility and offer their apologies to yourself for the inadequate response and explained that many of these issues arise from prior to their merger. They accept that they did not meet their obligations before the merger and have implemented measures to correct this.

In respect to your SAR the organisation have said that they will reprocess your SAR in order to provide you with the information you have requested. They also noted that they will contact you regarding this and would offer you the opportunity to redefine the terms of your SAR in order to include additional data that you may want to access.

The ICO accepts that this is an appropriate response to your complaint and are satisfied that they are implementing measures to improve their compliance with their data protection obligations. Therefore we do not deem it appropriate to take further regulatory action at this stage.

We keep a record of all the complaints raised with us about the way organisations process personal information. The information we gather from complaints may form the basis for action we may take in the future to ensure organisations meet their information rights obligations.

Thank you for bringing this matter to our attention. If you have any questions regarding the above please do not hesitate to contact me.

Yours sincerely,

Jay Ward

Case Officer

Information Commissioner's Office

The worrying phrase from the ICO:

Therefore we do not deem it appropriate to take further regulatory action at this stage.

But perhaps we can take comfort in:

The information we gather from complaints may form the basis for action we may take in the future to ensure organisations meet their information rights obligations.

In conclusion

GreenSquareAccord just had their wrists slapped, they can almost without fear continue to mismanage data, fail to keep track of customer communications. It’s easier to admit to this fault than to own up to far worse short fallings.

In September 2020 it was blamed on GreenSquareAccord’s inability to effectively communicate between internal departments. Now the issue has been widened to include many departments across two former housing associations that have merged into one.

Why are these organisations allowed to merge if they are unable to make a smooth transition, if it means customer will be negatively affected, if records will be lost? But more worrying, who benefits?

Is GreenSquareAccord really a not for profit?