Re the question raised by Paul Simpkins I would concur with the idea of
"standing firm" on manual data (as long as processing was not started after Oct
98, of course). The latter point illustrates the value of some kind of
preliminary audit, both in itself - legal reasons - and also as a form of
consciousness-raising exercise among staff.
The question raised by the person described in the original query has a
thinly veiled threat, to my mind ("it would look silly in the press...").
Here again it is important for organisations to be quite clear about what the
law requires, and to assure press or any other enquirers that they will be
complying with it. While on the one hand there is much to be gained from
openness and from going beyond what is necessary (I could imagine pre-empting
enquiries by merely sending out currently-held material to all staff for
checking), I do think that to give in on something like manual data which is
specifically exempted would be to give oneself a heap of trouble in subsequent
months.
Trevor.
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Dr Trevor Field
Senior Assistant Secretary
University of Aberdeen
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