Dear Roger,
1. I agree, but any web posting is outside the EEA. I was not too aware when
I signed up for this list that it was accessible via the web, (I subscribed
straight to the mailing list software from a link in Chris Pounder's Data
Protection & Privacy Newsletter), but I don't hold it against him that I
wasn't too aware.
2. Given that I've seen people harassed through their work e-mail (and an
inference of their racial grouping and sex given their e-mail address), I'm
inclined to regard any e-mail address which has your name in it as personal
data.
5. With any web distributed personal data I don't worry about the
legitimate, target users, but others who may see it and may cause me harm.
Principle 7 applies even if you have data subject consent to address
Principle 8; though what Jiscmail can do about protecting me in this
instance must be limited. All that can be done is warn us that this e-mail
is accessible from countries where the rights of data subjects may not be
respected, (as the DPC puts in her guidance paper on Principle 8). I then am
careful of what I say about certain matters.
Regards,
Andrew
Global IT Security & Data Protection Officer
The British Council
-----Original Message-----
From: Roger Cook [mailto:[log in to unmask]]
Sent: 25 January 2001 16:41
To: [log in to unmask]
Subject: Re: Mirroring of discussion list archives
Dear All,
Yes an interesting problem. Herewith a contribution for discussion.
1. The data transfer to Turkey will be outside the EEA so should be
subject to informed prior consent.
2. An email address is "personal data" in some circumstances. The one I'm
using here is not because the nature of my job means that it is a public
one. Others in the group may have private ones and these need permission.
3. I don't think we should hamper the acquisition of knowledge by any
student and, dare I say it, Turkey is struggling a bit with its EU
membership because of its Human Rights record so access to the data here
may be beneficial.
4. The student supervisor has taken the best first step of asking. When
this occurs, my reaction is always to say that the person is establishing
legitimacy. If they were not "legal decent honest & truthful" they would
have just done it!
5. There is nothing that I have posted that would cause me any concern
should any Turkish student read it.
6. So on balance, I would be in favour of the data transfer.
But perhaps there are contrary opinions?
Roger Cook
______________________________ Reply Separator
_________________________________
Subject: Mirroring of discussion list archives
Author: Adrian Tribe <[log in to unmask]> at Internet
Date: 25/01/2001 15:20
Dear colleagues,
I have been asked by someone in Turkey whether he can mirror on
his local (public) Web site the messages sent to a jiscmail list
that I own, so that the students and staff at his academic
institution can follow the list without clogging up his limited
bandwidth by all being subscribed individually. It all sounds
very worthy etc, but...!
His argument is that as there is already an archive accessible
world-wide from the jiscmail.ac.uk Web site, there aren't really
any further DP considerations. I'm not happy with that argument.
At the very least I feel I would have to inform the list members
that personal data (name and e-mail address at least) of
contributors would be being stored and displayed via a Web site in
Turkey as well as the UK, although how would I deal with it if
someone objected? What other issues should be considered here?
On one level I realise that this is all rather petty stuff, and for
all I know, this sort of thing is going on all over the place, but
as the list owner in this case, I would like to try to do the
right thing!
Thanks.
Best wishes,
Adrian
Adrian Tribe <[log in to unmask]>
List owner, [log in to unmask]
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