Compliance in debt collection: privacy, communication and auditability

Professional debt collection is a compliance discipline. This post highlights what “serious” looks like: data minimisation, respectful messaging, clear evidence and robust vendor governance.

January 24, 20262 min readBy Amadeus Romeo
InkassoCompliancePrivacyDatenschutz
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Focus and scope#

This note treats debt collection as a compliance discipline: when high case volumes meet sensitive data and emotionally charged situations, the risk of mistakes (tone, privacy, evidence) is real. Professional debt collection therefore means: standards, logging, and transparency.

As context: several formal metrics increased recently (2024 vs 2023). That raises the importance of clean processes. [BFS T 06.02.03.02; BFS T 06.02.03.03]

chart yoy 2024 key metrics
chart yoy 2024 key metrics

1) Privacy: data minimisation is not optional#

Without going into detailed legal bases, three principles are central:

  • Data minimisation: process only what is necessary for clarification and recovery (no “curiosity data”).

  • Purpose limitation: do not re-use data across purposes (e.g., marketing) when the purpose is debt recovery.

  • Transparency: communications should explain what is being requested, why, and how to raise questions/objections.

Operationally, this means: clean data models, access minimisation, a clear retention/deletion logic and documented processes.

2) Communication: respect is a control system#

Many complaints do not arise from the claim itself, but from how people are approached.

Professional standards:

  • Clear content: reference, amount, due date, next steps.

  • No intimidation: instead, factual information about possible next stages.

  • Accessibility: simple channels for questions, objections and payment plans.

  • Error handling: if something is wrong (address, invoice, service), it is corrected — not “pushed through”.

3) Auditability: every stage must be reconstructible#

A robust collection system can evidence:

  • Which documents support the claim (contract, invoice, service evidence).

  • Which contacts/deadlines were set (who, when, how, content).

  • Which agreements were in place (payment plan, instalments, conditions).

This matters not only for disputes, but also for quality improvement: what gets paid, where objections arise, which templates work.

4) Vendor governance (if external agencies are involved)#

When external partners are used, governance becomes more important:

  • Clear roles: who may communicate what, who decides escalation.

  • Quality criteria: tone, response times, documentation standard, complaint handling.

  • Monitoring: sampling, KPIs, audit trails.

Takeaway#

Serious debt collection is “professional process design”: data-minimising, respectful and auditable. If you treat it as a compliance discipline, you protect reputation and improve recovery through clear, fair communication. [BFS T 06.02.03.02; BFS T 06.02.03.03]

References#

Regulatory notice#

This publication is provided for information purposes only and does not constitute legal, tax or investment advice. It is not an offer, solicitation or recommendation. It is directed solely at qualified investors in Switzerland and is not intended for U.S. persons.

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In this series

Debt Collection in Switzerland

Part 6 of 6
  1. 1
    Debt collection (Inkasso) in Switzerland: why it matters — and why it is not a taboo
  2. 2
    Debt collection, debt enforcement and bankruptcy: the Swiss process in one overview
  3. 3
    What the numbers show: payment orders and bankruptcies in Switzerland (1994/1995–2024)
  4. 4
    2025 law change: “debt enforcement leading to bankruptcy” — why earlier resolution matters
  5. 5
    A practical playbook: early intervention, payment plans and de-escalation
  6. 6
    Compliance in debt collection: privacy, communication and auditability

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Regulatory notice

This material is for information purposes only and does not constitute investment advice, an offer, or solicitation. It is directed exclusively at qualified investors and is not intended for US persons.