I like the concept of it however it's bad from a customer point of view, Harzem is a good guy with good intentions but if I get wrongly tagged just because someone does not like me how do it I get it removed, there is no process, no way of me knowing my data is in fraudrecord unless the provider who rejects me or put me there says something.
And aside from that what data protection? I am all for using tools to spot the abusers but not at the price of blatantly dodging the legalities of it all, in fact no provider in the EU should even be using it as they breaking the law.