This has been a very interesting debate (so far) and it appears that opinion
is split probably down the lines of our own personal preferences.
"Would you like your details to be passed all over the world?" is the
question being asked by the opt-in lobby.
Some organisations are posing: "If you have an objection to your details
being sent round the world, let us know."
Presumably the people who are being sought by violent ex-spouses, stalkers or
debt collectors (whether across the world or just round the corner) will not
choose to have their details published. The problem with an opt-out system
is they may not receive the message, or they may not realise that "on the
website" means "worldwide".
In view of this possibility, plus the impending Human Rights Act, the Unfair
Contract Terms Act (one suggestion was to make it a condition of employment)
and various other pieces of legislation affecting public bodies (or those
undertaking a public function) I would suggest the following:
1) Give all employees who may need to be contacted by outsiders an e-mail
address that does not identify them, e.g. [log in to unmask];
2) Inform all staff that the organisation's intention is to publish
worldwide a list of e-mail addresses that are useful for external
organistions, applicants, whatever, so they can make enquiries, etc, but warn
them it will be seen in places that have no DP law and (frankly) poor human
rights records;
3) Give employees the option to change that address to their own name, e.g.
[log in to unmask] - but only after step 2) above;
4) Inform staff that after changing their e-mail address to one that
identifies them personally, they can have it changed to something else if
they encounter any difficulties or problems.
Although not strictly required in law, this should prevent some of the
problems that have been suggested during this debate.
Ian Buckland
MD
Keep IT Legal Ltd
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