The Children's Society has recently initiated a Data Protection Audit and as
a result several members of staff within the organisation have already
raised some significant issues.  One major concern is about the
anonymisation of data (Trevor Field has also recently raised this issue in
his email 'Third Party Agreements'); questions have arisen regarding the use
of sensitive personal data extracted from existing care files concerning
children and young people. These files are created by the organisation's
social work projects to document the work undertaken with these individuals.


While the Society has an ethical policy of only releasing identifiable
personal care data to professional parties involved in a case, the
organisation's PR department often asks social work staff to provide
anonymised factual information about children and young people for use as
case study material in the context of research projects, advertising
campaigns or for public relations purposes.

Given this, would list members have views regarding the operation of the
Data Protection Act for this practice: 

a) Is the anonymisation of such data sufficient to permit its use? Do we
have to obtain the consent of the data subject before doing this? The use of
personal data, extracted from care files, for case studies and research is
often an ad hoc procedure: it is not known at the point of collection that
the data will be used for these purposes. Would consent need to be obtained
from the data subject at the point of collection 'on the off-chance' that
the data may be used in an anonymised version at a later date, maybe years
down the line?

b) Would the amalgamation of data extracted from several data files and the
creation of an anonymous 'fictional' data subject be an acceptable way of
ensuring anonymity for each individual?

c) An added problem here is that often the cases are harrowing, dramatic and
involve various people, over and above the data subject (e.g. relations,
friends) . Even if a case is anonymised what is the situation regarding
these third parties? What if they recognise the events described in the case
study as being the one they were involved in and raise a complaint? Does
this have consent or use of data implications?

Feedback on any of these questions would be greatly appreciated.

Philippa Ireland, Data Protection Assistant, & Ian Wakeling, Records Manager
and Archivist	

The Children's Society Records and Archive Centre
tel: 020 7232 2966; fax: 020 7252 3902






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