I'm an employee (software developer) for a company that acts a data processor, and the company that is a client and data controller has requested a feature that I find questionable.
The purpose is to provide a client terminal inside a point of business that would function as follows:
- The customer arrives to the shop,
- the customer presses 'Start' button on a touch screen,
- enters her phone number,
- after this she is to be shown a greeting that includes her given name,
- customer selects what services she wants in order to complete the service order,
- and customer is called out by her given name when she is to be serviced.
My assumption is that should not be done, and if not illegal, then this would be at least seen rather bad manners. My assumption is based on the fact that the personal data (given name, existence of customership) may be handed to someone that has no legal right to see that data, and it might be impossible to name that person later on if needed.
As far as I can see it, if someone enters her phone number incorrectly, or for some reason enters a phone number that belongs to someone else, then it is possible that the given name belonging to someone else is shown.
Also due to the location (population 5,5 million), some foreign given names can be rare to such extent that they are unique within the country.
Since the phone numbers are recycled, it might be possible that a new customer sees the given name of previous owner of the number if the previous owner has also been a customer.
I doubt there is any other possible harm to customers expect possible loss of privacy that doesn't cause tangible damage, the services provided are not associated to sensitive matters.
So, is giving out customer name and implied existence of customership legal?
Edit 1 The phone number in question is probably expected to be a personal mobile phone number. It should be possible to verify that a phone number is a mobile phone number. I don't know if people sharing a mobile phone has been taken in to consideration.