Whilst I understand the concept that the references to Named individuals are
not in any index or order, I am dubious whether they are exculded from being
personal data under the act in the context of data subject access.
The act no longer requires the "processing" or access to the information to
be "" by reference to the data subject"".
So are odd references like this, in meeting minutes, signatures allocated on
stores issue notes or names identified as part of expenditure files to be
searched for and found to provide a complete data subject access request.
Any other interpretations for the implications of the deletion of the phrase
" by reference to the data subject" in the 98 Act?
If passing references do have to be included, data subject access requests
take on a completely new dimension.
Any comments anyone?
> -----Original Message-----
> From: Sandra Eastaugh [SMTP:[log in to unmask]]
> Sent: 19 May 2000 11:40
> To: Subject: Filing Systems
>
>
>
>
> I agree - if you can find it easily and know what it is, then it must
> be a filing system. This is the basis on which I am preparing to
> carry out audits for Depts in Norfolk County Council.
>
> I have piloted a couple of sections and we have listed the manual
> filing systems which contain personal data - there's not that many.
> Once you begin the exercise it gets easier. Lots of our files do not
> have personal information in them e.g. minutes of meetings,
> Committee reports etc.
>
> Sandra Eastaugh
> Senior Consultant,
> ICT and Exchequer Client Support Group
> Telephone (01603) 223856
> [log in to unmask]
>
>
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