** Reply to note from "Amber Thomas" <[log in to unmask]> Thu, 20 Jul 2000 15:42:20 +0100


> So my take is this: 
> Data on the web contravenes the eighth prinicipal, by definition.=20 
> If data on the web is not displayed already in printed form then you need = 
> the data subjects explicit consent. 
> If data on the web is already displayed in printed form, you do not need = 
> explicit consent BUT the data subjects must be informed of this use of = 
> their data and they have rights to object  (that seems like a kind of = 
> half-way house)

Can I take a slightly different view point as to what we should expect 
from a code of conduct.  It is no good putting on a DPO's hard hat saying
to people what they cannot do, nor should we be looking for ways to
increase 10 fold the bereaucracy in the hope of being compliant.

Universities traditionally published (in print on paper) the
University Calendar.  It is a silly idea that because we put on paper
something we can therefore put it on the web because then I can put on
paper EMail and Telephone addresses of all staff and therefore justify
putting it on the web.  It is equally silly to try and apply the rules to
the letter if the DPC is willing to give us a way out.

I asked this list many yonks ago about external email directories and I
received from my "learned" colleagues sufficiently sound advice.  If I
ever get round to doing the job and unless by then I know different the
intention is to:
1. Email the staff and ask them to opt in/out ... whatever.
2. Repeat the step above for non-respondents
3. Write to them on paper
Do the damn job by opting in the non-respondents.

Those who respond ... there is no problem whatever their response.  Those
who don't respond (I suspect will be the majority) we are prepared to put
in any such directory.

Breaking the law?  Maybe!  

What is the alternative?  Thousands of pieces of paper, more c**p flying
out to academics, let us not pay them to teach, let us pay them to tick
silly boxes.  We have to obey the law and similarly we have to be
accountable for spending public money.

In an ideal world we shall have a system where people could go and change
their preference as they like ... they can opt in today, opt out tomorrow.
In the meantime and until we all get to the 21st Century I find hard to
believe that when we are given a solution because it may carry a small
risk (ie. the DPC will not speak on our behalf if we end up in Court)
we should shut shop, roll over and give up.

I thought the whole idea of establishing a code of conduct is to give
guidance as to what we can/cannot do and then WE CAN ALL DANCE TO IT.
Now, if some would prefer not to dance, fine. Please don't shout how
bad the dancing of the rest of us is.  At least we are trying.

Whatever happened to strength in numbers and collective responsibility?

(And all this for just Email addresses on the Web.  Yuk.)

Charles

==============================================
Charles Christacopoulos, Secretary's Office, University of Dundee, 
Dundee DD1 4HN, (Scotland) United Kingdom.
Tel: +44+(0)1382-344891. Fax: +44+(0)1382-201604.
http://somis.ais.dundee.ac.uk/
Scottish Search Maestro http://somis2.ais.dundee.ac.uk/


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