# An Post wants to see a full bank statement before setting up a direct debit



## turnipcats (5 Feb 2014)

TV licensing appear to be insisting you now have to send a bank statement (and it must be a full one, not a mini-statement) if you are setting up a direct debit

Can this be true? It seems like a step backwards.

Surely an improved direct debit system should give _less_ information to the payee, not more?

From the "TV License Direct Debit" page of An Post's website: 

http://www.anpost.ie/AnPost/MainCon...n+Post/TV+Licence/TV+Licence+Direct+Debit.htm

_
TV Licence Direct Debit information
You can pay your TV Licence fee through Direct Debit from you Bank Current Account 
Important announcement:
A New SEPA TV Licence Direct Debit application and mandate form will be introduced from November 14. From this date onwards you must use this form when making an application to pay for a TV Licence through the TV Licence Direct Debit scheme. It will also be mandatory to provide a recent bank statement with your application. 
" _


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## Brendan Burgess (5 Feb 2014)

That is extraordinary. 

Why should one be obliged to disclose such financial information to An Post to pay a license fee which is mandatory? 

Brendan


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## T McGibney (5 Feb 2014)

Any such request should be notified to the Data Protection Commissioner's office.


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## Mrmr (5 Feb 2014)

I thought this was crazy when I noticed it last month also.
Is it to put people off Direct debit, I know it did put us off.


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## Locke (5 Feb 2014)

Totally agree with T McGibney



> _"the data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they were collected or are further processed"
> - section 2(1)(c)(iii) of the (DP) Act_




It would interesting to see the Data Commisioners view on this.


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## Brendan Burgess (5 Feb 2014)

T McGibney said:


> Any such request should be notified to the Data Protection Commissioner's office.



I have reported it to the An Post Data Protection Coordinator, via their Press Office. 

They should be given an opportunity to fix it before escalating it to the authorities. 

Brendan


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## Gerry Canning (5 Feb 2014)

Could be as simple as An Post want to clearly verify the customers  Sepa Direct Debit Details ,so that instead of the old sort code eg 90-47-21 account number 34325643.
that we used to use on Direct Debits We now have to use
BIC number eg ie boe11e2d... and IBAN bofi 90495334325643.

In short,given the large number of digits ,it is  too easy for customers to present one digit incorrectly and that would foul up systems and mean reworking.
If An Post can say  they only need  statement with IBAN , BIC and address attached, that may solve it.


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## Dearg Doom (5 Feb 2014)

The IBAN has a (simple) error checking mechanism built in so an error with a small number of digits would easily be caught in entering the data (e.g. check out the IBAN validator at http://www.ibanvalidator.com/en/ - enter your bank details at your own risk!).


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## DMcL1971 (5 Feb 2014)

In their FAQ it says:


*Why do I need to supply a copy of a bank statement ?*
A copy of a bank statement (non-returnable) is required to verify the bank account details provided by the Licencee for payment of their TV Licence Fee. 

*Note:* The bank account statement must have the BIC, IBAN, account holders name and account holders address, therefore mini statements are not acceptable.



On their actual DD mandate it further says:

*Required Documentation 
*[FONT=Calibri,Calibri][FONT=Calibri,Calibri]You are required to submit a recent bank statement with this Direct Debit application (copy of statement will suffice). The bank statement must show the address of the Bank Account Holder and that there are sufficient funds in the account to support this Direct Debit Agreement. 
[/FONT][/FONT]

This second statement seems particularly ridiculous to me, for two reasons. Firstly the balance on a recent statement has no bearing on whether there will be money their account when the DD is taken. Secondly, the bank account address can be different to both the postal address of the customer and the address of the TV licence. In fact because it is SEPA it can be anywhere in Europe.


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## theresa1 (7 Feb 2014)

http://www.independent.ie/irish-new...ng-bank-details-for-tv-licences-29987601.html

"AN INVESTIGATION has been launched by the Data Protection Commissioner after it emerged An Post is making people reveal the contents of their bank accounts just to pay their TV licence."


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## Brendan Burgess (7 Feb 2014)

Brendan Burgess said:


> I have reported it to the An Post Data Protection Coordinator, via their Press Office.
> 
> They should be given an opportunity to fix it before escalating it to the authorities.
> 
> Brendan



Maybe going directly to the Data Protection Commissioner was the best idea.

I have received no reply, not even an acknowledgment.


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## Bronte (7 Feb 2014)

As you guys know I live abroad, and we too have Sepa, I changed bank last year and for the last few months have been changing direct debits. Not once was I ever asked for a bank statement. All the utilities, phone, tv, internet, electricity had basically a standard form to fill out. 

Only needed my name, address, bank account IBAN and BIC. Not name of bank, nor address of bank, nor copy of bank statement. 

This demand from An post is patent nonsense. And it's none of their business what is in your bank statement, not is it their business if you have enough money in the account to pay a direct debit. 

Apart from the Data protection mentioned on this thread, I imagine that the An post demand contravens the requirements of Sepa.

Does any utility company in Ireland ask for the same detail?


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## Gerry Canning (7 Feb 2014)

Dear Bronte; 

Could it be An Post believe we have trouble transcribing 11 or damn it ,is it 12 numbers, as we Irish make mistakes so easily?
(forgive my humour)!


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## Leo (7 Feb 2014)

Gerry Canning said:


> Could it be An Post believe we have trouble transcribing 11 or damn it ,is it 12 numbers, as we Irish make mistakes so easily?
> (forgive my humour)!



That's their excuse according to the Indo article...with SEPA, mistakes are more expensive to rectify!


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## Bronte (10 Feb 2014)

If they need documentary confirmation of the bank acount number, the IBAN all one needs to do is photocopy the bank statement without the transaction details.  Alternatively one can print off from internet banking those details without the transactions.


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## Leo (10 Feb 2014)

Bronte said:


> If they need documentary confirmation of the bank acount number, the IBAN all one needs to do is photocopy the bank statement without the transaction details.  Alternatively one can print off from internet banking those details without the transactions.



If you mask transaction details you may not meet their criteria for being able to demonstrate 'there are sufficient funds in the account to support this Direct Debit Agreement.'

Also, online statements often don't show 'the BIC, IBAN, account holders name and account holders address.'


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## Time (10 Feb 2014)

Their criteria is unlawful in my opinion.


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## Brendan Burgess (20 Feb 2014)

Got a reply just now...

Dear Mr Burgess


[FONT=&quot]Current Position 
 Many thanks for bringing your concerns to An Post’s attention. I  set out our response to your recent website comments about An Post’s  Direct Debit TV Licence payment option. On commercial grounds, An Post  has decided to no longer seek proof of funds in the bank account on which a direct debit is being established. The  tvlicence.ie website and mandate form text are being amended to reflect  this change.

[/FONT]
[FONT=&quot]Position at Date of your query
 We believe that An Post’s direct debit scheme for TV Licence  payment complied with data protection law at the date of your comments.  Our analysis was as set out below.

 Under SEPA rules, responsibility for setting up Direct Debit  mandates now rests with the originator – i.e. An Post. We are  responsible for ensuring that this information is accurate, complete and  up-to-date for commercial and data protection reasons. This requires use of the customer's BIC and IBAN codes - both of which are  lengthy number sequences with which the customer is usually quite  unfamiliar, giving rise to a significant margin for error. An Post can  only be advised of these by the customer and banks no longer verify these details as part of the transaction. Where an  error occurs and the payment cannot be processed, the originator is  liable for a sizeable, per incident, fee - in addition to the loss of  the due payment. In a case where a wrong digit results in the money being taken from an incorrect account, the originator must  bear this loss, as well as the cost of correcting the error when it  comes to light. This is why An Post is taking additional steps to ensure  the accuracy of the BIC and IBAN codes at the critical point when the DD mandate is being set up. We believe we are  seeking the minimum data required to operate the service and that we  comply with data protection law.

 We ask for a full bank statement so that we can also be sure that  there are sufficient funds in the account to cover the initial payment.  Again this meets the data protection requirement to request the minimum  amount of data to provide the service.

 Bank statements are securely shredded by An Post after the first debit is successfully processed.

 While it is mandatory to have a TV licence if you have a TV set; it  is not mandatory to pay the fee by direct debit. As noted below, it is  one of a number of payment options available. The level of personal data  sought for each payment method reflects the nature of the payment method and its credit risk to An Post. For  example, less personal data is requested from customers who renew their  licence by paying cash or TV Licence stamps than for the direct debit  scheme. An Post limits the personal data sought to the minimum necessary to provide each payment type.

 The licence may be paid: 
 by cash or debit card at the Post Office; 
 by debit or credit card online or over the phone at LoCall 1890228528;  
 by cheque to the local TV Licence Office;  
 by saving up for a licence by purchasing TV Licence Stamps 
 and by cash at selected PostPoint outlets 


Yours sincerely

Tom Hulton

Data Protection Co-Ordinator
An Post
[/FONT]


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## Brendan Burgess (20 Feb 2014)

I am glad that they no longer are asking for the full bank statement.  Fair play to them for not attempting to defend the indefensible. 

I think it's completely reasonable for them to ask to see the full IBAN and BIC as supplied by the bank.  It must be very time consuming and expensive to fix such errors.



> In a case where a wrong digit results in the money being taken  from an incorrect account, the originator must  bear this loss, as well  as the cost of correcting the error when it  comes to light.



This is Brian Lucey territory.  The originator is not incurring any "loss" by taking the money from the wrong account. They are profiting by it. Of course, they do incur a significant cost in fixing it.    It would be different if An Post was making payments - they would be bearing a loss if they made a payment to a wrong account and could not recover it. 

Brendan


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## DMcL1971 (20 Feb 2014)

Brendan Burgess said:


> Got a reply just now...
> 
> 
> Under SEPA rules, responsibility for setting up Direct Debit mandates now rests with the originator – i.e. An Post. We are responsible for ensuring that this information is accurate, complete and up-to-date for commercial and data protection reasons. This requires use of the customer's BIC and IBAN codes - both of which are lengthy number sequences with which the customer is usually quite unfamiliar, giving rise to a significant margin for error. An Post can only be advised of these by the customer and banks no longer verify these details as part of the transaction. Where an error occurs and the payment cannot be processed, the originator is liable for a sizeable, per incident, fee



Fair play Brendan. 

 I agree that there is a far greater margin for error on the customers part when entering BIC/IBAN details onto any form. However I still wouldn't be keen on sending in any paperwork to prove these details. It would seem more reasonable to me, for AnPost to inform the customer that if they provide incorrect details they will incur an additional fee or penalty of some sort.


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## Brendan Burgess (20 Feb 2014)

It will be interesting to see how other DD originators handle it. 

Brendan


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## Sue Ellen (20 Feb 2014)

Brendan Burgess said:


> Got a reply just now.


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## Dearg Doom (20 Feb 2014)

DMcL1971 said:


> I agree that there is a far greater margin for error on the customers part when entering BIC/IBAN details onto any form.



There may be a chance of error but these can be verified brefore processing any transactions. If the customer is asked for the BIC as well as their bank name and address then these can be confirmed to be a match via online look-up. If not then the BIC is wrong. The IBAN has an error check built in to ensure the accuracy of the number (see Wikipedia for all the gory details) - not perfect but I imagine it would catch most entry errors.


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## Mrs Vimes (20 Feb 2014)

Brendan Burgess said:


> We ask for a full bank statement so that we can also be sure that  there are sufficient funds in the account to cover the initial payment.  Again this meets the data protection requirement to request the minimum  amount of data to provide the service.



This sounds to me distinctly like trying to defend the indefensible.

Will they refuse the DD if the statement is from the period after paying the Christmas CC bill but before getting the January paycheck?

Well done on getting a response from them but I think you are letting them off far too lightly!


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## Brendan Burgess (20 Feb 2014)

Hi Mrs Vimes

That is their old policy. They have changed it as a result of the discussions on askaboutmoney. 

I agree that they should not be defending their old policy, but fair play to them for changing it.

Brendan


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## Brendan Burgess (20 Feb 2014)

Sue Ellen said:


>




http://www.memecenter.com/fun/1237111/bad-luck-brain-bowing-for-applause


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## RainyDay (2 Apr 2014)

Brendan Burgess said:


> We ask for a full bank statement so that we can also be sure that  there are sufficient funds in the account to cover the initial payment.  Again this meets the data protection requirement to request the minimum  amount of data to provide the service.
> 
> Bank statements are securely shredded by An Post after the first debit is successfully processed.





Brendan Burgess said:


> I am glad that they no longer are asking for the full bank statement.  Fair play to them for not attempting to defend the indefensible.



Am I missing something? They are still looking for a bank statement to pay by direct debit, right?

http://www.anpost.ie/AnPost/MainCon...n+Post/TV+Licence/TV+Licence+Direct+Debit.htm


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## Time (2 Apr 2014)

Sure looks that way.


> It will also be *mandatory to provide a recent bank statement* with your application.


Their bolding.


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## pmurphy (31 Oct 2014)

I bank with Ulster bank, I dont get paper statements anymore. I have no idea how to give this information to the TV License people!

Any help?

thanks


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