Retail Store Asking Customers for their Phone Numbers (2020-12-04)

Summary

This is a published case summary from the Cayman Islands Ombudsman describing an informal resolution of a data protection complaint against a retail store. A customer complained that a cashier asked for their phone number without explaining why, and objected to having to say it aloud in front of other customers.

• Security finding: The Ombudsman found the store's existing measures adequately mitigated the low security risk of collecting phone numbers verbally at the till.
• Transparency finding: The store had not told customers why their phone numbers were being collected, which was treated as a shortcoming under data protection transparency principles.
• Recommended fix: The store was advised to display signage at cashier stations or have cashiers verbally explain the purpose of collecting phone numbers.
• Additional recommendation: The Ombudsman also recommended the store publish a privacy notice on its website explaining all purposes for which personal data is processed.

This is an individual case outcome rather than a binding rule, but it illustrates how the Ombudsman applies data protection transparency requirements to everyday retail data collection practices.

Key obligations

• Businesses collecting personal data such as phone numbers from customers should inform data subjects of the purpose for collection, for example through signage or verbal explanation at the point of collection
• Businesses should maintain a privacy notice on their website explaining all purposes for which customer personal data is processed

Applies to

retail stores, data controllers