The preference services data lists which are made available under licence to
TP's to screen their marketing are as far as I am aware usually in a form,
from which it is not possible to identify a living individual.
MPS Postal objectors list use address and surname only
TPS Telephone objectors are just a list of telephone numbers
EPS Email objectors would just be an email id e.g KITLegal@aol,com. Try to
identify a living individual from just their email id and you will find it
is not possible without other data or assumptions.
Therefore until the list data is added to other data it is arguable that it
could sit outside of DPA as it does not on its own identify a living
individual. Sending such data to USA, safe harbor or not would appear to be
OK.
Any comments re flaws in my analysis appreciated.
Dave Wyatt
-----Original Message-----
From: [log in to unmask]
[mailto:[log in to unmask]]On Behalf Of [log in to unmask]
Sent: 08 September 2000 13:26
To: [log in to unmask]
Subject: Re: Preference Services
Thanks for the infor on the E-mail Preference Service, I understand the data
is transferred to the USA (which is definitely outside the EEA) - is this
done with informed consent of the data subject?
Ian
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