Reuse of pre-paid mobile number (2021-06-15)

Summary

This is a case summary published by the Cayman Islands Ombudsman describing an informal resolution decision on a data protection complaint. It is not a rule or regulatory requirement but an illustrative outcome showing how the Ombudsman applied the Data Protection Act's principles to a specific complaint.

• Complaint: An individual alleged that a mobile operator violated the first, fifth and sixth data protection principles by disconnecting his pre-paid SIM after inactivity and reassigning the number to another customer.
• Finding: The Ombudsman investigated and did not uphold the complaint, finding the operator acted lawfully under the customer agreement and had properly informed the complainant of the processing and its purpose.
• Reasoning: The phone number was considered the individual's personal data only for the duration of the contract, and reassignment occurred 60 days after the number became inactive, which was found not to breach the fifth or sixth data protection principles.
• Outcome: No further steps were required of the data controller.

As a case outcome rather than a binding instrument, this summary does not itself impose new obligations on regulated entities, but it signals the Ombudsman's approach to assessing lawful basis and data retention/reassignment practices by mobile operators.

Applies to

mobile network operators, data controllers