Dennis wrote on the issue of distribution of materials to staff (14/04/2000
11:40)
It appears to me that there are two DPA issues in the query:
a) Direct mailing
b) Trading in personal data
If you use the payroll list for distribution of advertising material (slips,
forms, leaflets, etc) for other organisations for a fee it is classed as
trading in personal data, even though the advertiser does not get a copy of
the list - they "hire" it from you. You must ensure you are registered for
this purpose (it was P018 under the old registration rules).
If you advertise products and services within the newsletter I would not
think it constitutes direct mailing and should be okay. People see adverts
in nearly all their magazines and newspapers. If they do not like the
publication (perhaps because there are more adverts than useful articles)
they will stop having it.
My advice would be to continue putting adverts in the newsletter but call it
a "magazine" so that staff do not get the (wrong) idea that the content will
be all work-related.
Ian Buckland
MD
Keep IT Legal Ltd
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