According to Circular No. 20-01, online lenders can only collect personal data they need for their “know your customer ” policies and in determining creditworthiness. However, they are prohibited from requiring unnecessary permissions that involve personal and sensitive information.
Once the photo has already been taken, the app should turn off the permission that allowed the lender access to the borrower’s phone camera. At the very least, the app should remind the borrower to turn off the permission such as through pop-up notices. “In no way shall the borrower’s photo be used to harass or embarrass the borrower in order to collect a delinquent loan,” the circular said.
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