The Central Credit Register is established by the Central Bank under the Credit Reporting Act 2013 (the “Act”). The Act obliges lenders to submit specified personal and credit information in respect of credit applications and credit agreements to the Central Credit Register. There is no obligation on lenders to provide any underlying documentation, such as credit application documentation, credit approvals or any other correspondence or documentation between a lender and a borrower in relation to credit applications or agreements. The provision of underlying documents and the accumulation of such documentation for all loans is not necessary to operate the Central Credit Register. Furthermore, the Central Bank has advised that if collected, it would constitute a disproportionate processing of data.
Under the Act and general data protection law lenders (credit information providers) are obliged to ensure that the information they submit to the Central Credit Register is accurate, complete and up to date. The Act, and general data protection law, also provides that a borrower (credit information/data subject), has a right to request the amendment of information that they believe to be inaccurate, incomplete or not up to date. The Central Credit Register has established processes at https://www.centralcreditregister.ie/borrower-area/submit-a-request/ through which borrowers can process amendment requests. Borrowers are encouraged to provide as much relevant supporting documentation as possible in the course of this request which is provided to the lender in question, with a request that they review their submissions to the Central Credit Register to ensure that the information being reported is correct. If a request to amend is unsuccessful a borrower may raise the matter with the Financial Services Ombudsman as a formal complaint.
Finally, data subjects (borrowers) may also request copies of their documents from a data controller (lenders), and may also raise the matter with the Data Protection Commission.