>
> It may be possible that you can do the job on an opt out basis, after
> sufficient warning has been given to your staff and they are
> invited to opt
> out. (Now I will be killed for saying that).
Charles
I think you're right. See the document - "JISC data protection code of
practice for the HE and FE sectors (ver 2.0)" produced by the Information
Law and Technology Unit at the University of Hull Law School.
http://www.jisc.ac.uk/pub00/dp_code.html
Section 13.2 - quote:
"Where staff on-line telephone and e-mail directories are made available on
the Internet, for the purposes of the normal organisational functioning and
management of the institution, this should not require the consent of data
subjects. However, data subjects whose personal data is used in this way
should be informed of this use and should retain the right to object to the
use of their data where it would cause them significant damage or distress."
So it seems the opt-out route is permissible, provided the institution makes
all reasonable endeavours to inform staff that they intend to do this at a
certain point in time and, furthermore, give staff the opportunity to
opt-out before their directory entry is made available on the internet. The
important phrase here is "normal organisational functioning and management
of the institution". Note, publishing _student_ email addresses does not
fall into this category and therefore explicit consent (ie opt-in) of the
data subject is required.
Regards,
Mike
--------------------------------------------
Mike Taylor, Project Manager
DELTA Project
The University of Manchester
188 Oxford Road, Manchester M13 9GP
t: 0161 2757330
f: 0161 2758333
e: [log in to unmask]
--------------------------------------------
DELTA - "Delivering the Electronic Learning
and Teaching Advantage"
http://www.delta.man.ac.uk
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