Services of credit bureaus under DORA

Do the services offered by credit bureaus fall within the definition of 'ICT services' as outlined in Article 3(21) of DORA? If so, can credit bureaus be considered as providers of ICT services under Article 3(19) of DORA?

Credit bureaus manage credit information systems. Essentially, a credit information system is a database that gathers and maintains credit history and credit-related details about individuals and businesses. The primary objective of a credit information system is to furnish credit reports and credit scores, aiding in the evaluation of credit risk and facilitating informed lending decisions. While specifics vary among companies, credit information systems typically involve computer and technological infrastructure to ensure the secure, reliable, and confidential handling of exchanged data.