Guidance on
Requesting Personal Information.
The following is a guidance to help make sure you get everything you want and need from Vodafone,
when you request your personal information. If you need help with filling out our form, please refer to
Section C below.
1) Subject Access Requests: Some basics to help you.
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The Data Protection Act, 1998 gives individuals the right to ask organisations that hold
information about them for access to that information. This right is called a ‘Subject Access
Request’ and we will refer to this as “SAR” throughout the guidance.
You can exercise this right at any time.
However before you submit a SAR to us:
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We would like to ask you to please make sure you have tried to resolve matters with our
Customer Services team, or have lodged an appropriate complaint / dispute, to give us an
opportunity to fix things, if we have got anything wrong.
As you can see from below, they can provide you some information without the hassle of
waiting for a SAR.
If you have tried and still believe the information we hold about you is not correct, or need it
to verify things then please use the Subject Access Request Form located here. It will help
make sure you get what you need as quickly as possible.
2) Who can make a SAR?
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The right to make a Subject Access Request only applies to individuals. This means:
 Living people;
 Sole trader businesses;
 Duly authorised persons acting on someone’s behalf (e.g. solicitor, carer, relative).
X
Business / Corporate Accounts:
 If you are a customer seeking any information regarding a business account,
we will not be able to assist you under this process.
 You should contact Customer Services, or your Account Manager.
X
Deceased customers:
 If you are the executor of an estate, and need access to information for
administration purposes, or a relative of someone who has passed away,
please contact our bereavement team.
3) Important information about what you need to provide to us for a successful SAR:
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You must make your subject access request in writing, and include:
Sufficient information to enable us to identify:
 Your account;
 Enough details to help us locate the particular information you are seeking such
“account notes” or “call recordings”. Please see the sections below for what
information we have about you to see if we even have what you are looking for.
Documentation to confirm your identity and that you are entitled to have access to the
information being requested;
Document duly authorising any third parties to making a request on your behalf and their ID;
The statutory £10.00 fee (postal order or cheque made payable to Vodafone Limited)
 Please note a payment of an additional £10.00 made to the account will not suffice
and may delay processing the request
Until we have all this we will not be in a position to deal with your request, nor are we
obliged to under the legislation.
You will find that completing Vodafone’s template form will help you make a successful
request and avoid any delays in it being processed.
Please see section X for assistance on how to fill out the Vodafone SAR form.
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We have 40 days from receipt of your SAR to respond and provide your information back to
you. We will try and respond as quickly as possible, but if you need your information sooner
please let us know, and we’ll try and accommodate this.
4) What information does Vodafone have on me?
In line with good privacy and data protection principles, Vodafone minimises the personal data it
collects about you.
Many people believe we hold much more information than we actually do and whether we can
provide you with what you want may depend on:
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The type of account you have with us,
The nature of the dealings that have passed between us; and
The services that you use.
Please read the information below carefully before making a request to ensure that we
actually hold the information you are looking for.
For an explanation of what information we may be able to provide to you:
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Please refer to Section A if you are a contract customer.
Please refer to Section B if you are a pre-pay customer.
Please refer to Section C on how to fill out our SAR form.
SECTION A)
INFORMATION HELD ON CONTRACT CUSTOMERS.
Information that is NOT AVAILABLE even under a SAR:
 Content of Calls, SMS, MMS or Voicemail
Vodafone is unable to provide you with information about the content of any calls, voicemail,
SMS or other messages. Vodafone does not record the content of the calls you make or the
wording of your messages.
 Copies of Contracts
We are unable to provide you with a copy of your signed contract. These are not held in a
relevant filing system. We can provide you with copies of your terms and conditions, please read
below for more details.
Information available from Vodafone, without needing to make a SAR:
 Copies of Bills
You do not need to make a SAR in order to get a copy of your bill.
Customer Services can provide you with a copy of your Vodafone bill (or several copies if you
need) You can contact them by dialling 191 from your Vodafone mobile or via the ‘”Contact Us”
page on our website: www.vodafone.co.uk. You may be charged for these.
 Information about your contract
Information about:
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The specific tariff you are on;
Your contract’s start and end dates.
These are available by contacting Customer Services. You can them by dialling 191 from your
Vodafone mobile or via the ‘”Contact Us” page on our website: www.vodafone.co.uk.
If you are seeking information about the terms of your contract, you can find the airtime terms
and conditions via the “Terms and Conditions” page on our website: www.vodafone.co.uk.
 Copy of Proof of Purchase (Receipts) for Mobile Handsets
You do not need to make a SAR, in order to obtain a copy of a receipt.
Customer Services can help you get a copy of your receipt (to prove purchase of your handset for
insurance or other purposes).
You can contact Customer Services by dialling 191 from your Vodafone mobile or via the
‘”Contact Us” page on our website: www.vodafone.co.uk.
Information that may be available through a SAR:
 Account notes and correspondence
The entries on the account notes are a summary of activity on your account generated either
automatically by the system, or as a result of your interactions with our customer service
agents.
Vodafone does not automatically keep a copy of all correspondence. Many letters or other
messages you receive from us are produced automatically, with just your contact details
inserted: actual copies may not be retained on our systems: instead a note is made to state that
a standard letter or notification was sent to you. When correspondence is kept, it will be
attached to your account and will be available by making a request for copies of your account
notes.
 Lists of calls and SMS / MMS made to and from your Vodafone Mobile Phone
You will be able to request lists of calls and texts made from your mobile phones.
We store detailed records of incoming calls, texts and other messages for a 12 month period
only.
We cannot provide you with details of incoming calls or messages older than 12 months.
We will not provide details relating to incoming calls, unless we have a Court Order. This is to
protect the privacy of the individual who made the call. Please see section at the end about
Court Orders if you need incoming call information.
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List of incoming SMS / MMS to your mobile phone.
Vodafone can provide you with a list of your incoming SMS / MMS for the previous 12 months
only.
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If you have been charged with a Driving Offence involving a mobile phone.
If you have been charged with a driving offence related to mobile telephone use, to assist you
in court Vodafone will provide you with your list of:
 Incoming calls without any originating numbers;
 Incoming SMS and MMS-es; and
 Outgoing calls, SMS and MMS-es.
Proof that you have been charged by the Police must be provided with your SAR. Vodafone will
only have the preceding 12 month of incoming call, SMS and MMS data.
 Copies of Call Recordings made to Vodafone Customer Services
Vodafone does not record all of the calls made to our call centres. Those that are recorded are
generally only retained for between 3 and 60 days. Because of this, the specific call recording
that you are seeking may not always be available.
SECTION B) INFORMATION HELD ON “PRE-PAY” CUSTOMERS:
For Unregistered Pay-as-You-Go Mobile Phone Numbers please note.
If your pay-as-you-go phone is not registered with us we cannot verify your identity and so we will
not disclose any information without a Court Order.
If you subsequently choose to register your account, you will only be able to access information from
the date of registration, but not prior to that date.
IF YOU ARE A REGISTERED PRE-PAY CUSTOMER:
Information that is NOT AVAILABLE even under a SAR:
 Content of Calls, SMS, MMS or Voicemail
Vodafone is unable to provide you with information about the content of any calls, voicemail,
SMS or other messages. Vodafone does not record the content of the calls you make or the
wording of your messages.
 Copies of Contracts
We are unable to provide you with a copy of your signed contract. These are not held in a
relevant filing system. We can provide you with copies of your terms and conditions, please read
below for more details.
 Billing Information
We are unable to provide itemised bills or details of call costs for prepay customers as we do not
store this information in our systems.
Information that may be available without making a SAR:
 Copy of Proof of Purchase (Receipts) for Mobile Handsets
You do not need to make a Subject Access Request in order to obtain a copy of a receipt.
Customer Services can help you get a copy of your receipt (to prove purchase of your handset for
insurance or other purposes).
You can contact Customer Services by dialling 191 from your Vodafone mobile or via the
‘”Contact Us” page on our website: www.vodafone.co.uk.
 Information about your contract
If you are seeking information about the terms of your contract, you can find the airtime terms
and conditions via the “Terms and Conditions” page on our website: www.vodafone.co.uk.
Information about the specific tariff you are on, as well as your contract start and end dates is
available by contacting Customer Services. You can them by dialling 191 from your Vodafone
mobile or via the ‘”Contact Us” page on our website: www.vodafone.co.uk
 Top ups and available credit
You can get information about recent top-ups and available credit by contacting Customer
Services (by dialling 191 from your Vodafone mobile or via the ‘”Contact Us” page on our
website: www.vodafone.co.uk).
Information that may be available through a Subject Access Request
 Account notes and correspondence
The entries on the account notes are a summary of activity on your account generated either
automatically by the system, or as a result of your interactions with our customer service agents.
Vodafone does not automatically keep a copy of all correspondence. Many letters or other
messages you receive from us are produced automatically with just your contact details inserted:
actual copies may not be retained on our systems: instead a note is made to state that a standard
letter or notification was sent to you. When correspondence is kept, it will be attached to your
account and will be available by making a request for copies of your account notes.
 Lists of calls and SMS / MMS made to / from your Vodafone Mobile Phone
You will be able to request lists of calls made from your mobile phones.
We store records of incoming calls, texts and other messages for a 12 month period only. We
cannot provide you with details of incoming calls or messages older than 12 months.
We will not provide details of incoming calls unless we have a Court Order. This is to protect the
privacy of the individual who made the call. Please see the section at the end about Court Orders
if you need incoming caller information.
 List of incoming SMS / MMS to your mobile phone.
Vodafone can provide you with a list of your incoming SMS / MMS for the previous 12 months
only.
 If you have been charged with a Driving Offence involving a mobile phone.
If you have been charged with a driving offence related to mobile telephone use, to assist you in
court Vodafone will provide you with your list of:
 Incoming calls without any originating numbers;
 Incoming SMS and MMS-es; and
 Outgoing calls, SMS and MMS-es.
Proof that you have been charged by the Police must be provided with your SAR. Vodafone will
only have the preceding 12 month of incoming call, SMS and MMS data.
 Copies of Call Recordings made to Vodafone Customer Services
Vodafone does not record all of the calls made to our call centres. Those that are recorded are
generally only retained for between 3 and 60 days. Because of this, the specific call recording that
you are seeking may not always be available.
SECTION C) ASSISTANCE WITH FILLING OUT THE VODAFONE SAR FORM.
Please find below some helpful hints and tips to make sure you get a successful SAR and a great
experience from Vodafone.
Please insert your personal details
here. This will help us identify who
you are. If you choose delivery by
email, we will send to this address.
Please provide us with the mobile
number(s) / account number to
which your request relates.
Authorised users on Account.
Please let us know if people other
than you have additional numbers
on your mobile phone account. (E.g.
wife, children) and which mobile
number is theirs. If you are asking to
have their information too, please
also see section on Authorisation
below.
Please tick which type of mobile
phone account you have. We cannot
provide data about unregistered pre
pay mobiles without a Court Order.
Please tick this box if you don’t want
your SAR returned by email. If you
don’t tick this box, we will return it
to you via the email you have
provided above on the form.
Date Range:
Vodafone asks you to give us a date
range between which you would
like to receive your personal data.
This is very important as some
accounts that have been for a long
time will have lots of data. If you
limit your request, it will reduce the
amount of things you need to read
through. Think of the date of the
event that led to your make your
SAR and allow for a buffer on either
side.
E.g. Let’s say you opened your
account in 2001. The issue which
you want information about
happened on: 10/1/2014.
 Then with a small buffer if you
put “8/1/2014 TO 12/1/2014”
we can provide relevant
materials, instead of years of
irrelevant things.
Please tick which categories of
personal data you would like
Vodafone to provide between the
date ranges you have specified.
Each of these items are discussed in
detail in this Guidance. Please note
for incoming calls with originating
numbers Vodafone will require a
Court Order. Please see the
following section on Court Orders
for further information.
Please return your SAR to this
address to minimise any delays in
processing its contents.
Declaration and checklist.
Please make sure you have:
 enclosed and checked the
required documents;
 understood the declaration;
Authorisations:
If you are making a SAR on
someone’s behalf, or if you need
access to an authorised account
user’s information as part of your
SAR, you will need their authority
for Vodafone to disclose their data
to you.
Please make sure your authority:
Sign and date
Please don’t forget to sign and date
your SAR.
 clearly identifies the account
holder or authorised users; and
 clearly states that they are happy
for Vodafone to disclose their
personal information to you.
SECTION D) COURT ORDERS AND INCOMING CALLS.
Vodafone will only disclose incoming call data with originating numbers with a court order. This is to
protect the privacy rights of those third parties that have called the mobile phone, but are not in a
position to give consent to their data being disclosed.
This position will not be deviated from, so you will need apply to a Court and justify why you need
incoming calls with telephone line identification.
Please note that Vodafone only retains this information for 12 months, requests outside this
period will not be able to be complied with.
This position applies to solicitors equally as it does to customers.
There are important things to make sure when you are applying for a court order that will reduce
the chances of Vodafone rejecting the court order, and asking for further clarification.
Unfortunately the orders we see at times although well intentioned, fail to create the direct legal
obligation on Vodafone to disclose incoming call data. In these instances Vodafone regrettably has
no choice but to return the order and ask that you reapply for it in the appropriate terms.
To avoid this and any unnecessary delays, please follow the guidance below and use the draft
wording.
The order must:
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State and properly identify who the data subject is and whose call records are to be
disclosed.
 Solicitors and customers please note: If you are seeking incoming calls to an
unregistered Pre-Pay mobile, i.e. one that has not been registered with Vodafone as
belonging to a specific person, then please do not refer to the mobile in the order as
belonging to a specific person. E.g. “Vodafone Limited shall disclose incoming calls to
Joe Bloggs’ mobile 07700 000 000.” Vodafone will have no information to suggest
that the number belongs to Joe Bloggs and because of that we’ll have to reject the
order. If you are unsure whether the Pre-Pay mobile has been registered, then
please omit all references to ownership of the mobile by a specific person to ensure
Vodafone can disclose the requested materials at speed.
Apply to the data subject’s mobile carrier at least, but ideally it should also refer to
Vodafone by name and state that the order applies to Vodafone Limited directly.
 Orders directing solicitors to obtain and disclose documents are not acceptable or
deemed valid for this purpose.
List ALL of the type of communication data sought. Bear in mind that Vodafone will rely on
the court order to disclose all personal data to you. Therefore although
 Incoming / outgoing calls
 Incoming / outgoing SMS and/or MMS
 Mobile Data Usage reports.
 Location data
State the range of dates between which disclosure of the information is sought.
 E.g.: “The above types of data are requested from 1/2/2014 to 2/2/2014.” Dates are
interpreted to be inclusive.
Signed and/or sealed.
Draft wording for Court Orders:
The court hereby orders Vodafone Limited to disclose as soon as practicable to the [Applicant]
[Applicant’s Solicitors] [Mr/Mrs/Ms XXXXXX] [Respondents] [Respondent’s Solicitors] [Please
delete as appropriate] the following items of personal data within its control, related to mobile
phone number[s] [07700 000 000] from the date [XX/XX/XXXX] to [XX/XX/XXXX] inclusive:
[Please delete as appropriate]
1)
2)
3)
4)
5)
6)
Incoming / outgoing calls
Incoming / outgoing SMS / MMS
Mobile Data use records
Location data held
Call recordings
Account notes
Service shall be electronically to the following email address: [Please insert email address for
service] or to the following address [Please insert address for service]