At 12:23 19/12/01 +0000, Su Goulding wrote:
>Financial Times article 18/12/01 re: OIC employer/employee guidance,
>specifically regarding disclosure of interview notes to candidates is at:-
>http://news.ft.com/ft/gx.cgi/ftc?pagename=View&c=Article&cid=FT343DP8EVC&liv
Isn't the key issue here what information is being held (in a structured
filing system) in relation to a data subject at the point where that data
subject makes a subject access request?
If (as has been the practice here for several years) interview notes are
regarded as something to help the actual selection discussion part of the
process, as distinct from the interviews which precede it, and are
collected up once this finishes (and destroyed immediately), then there
wouldn't be anything on file for the subject to have access to.
This doesn't, I respectfully suggest, infringe any concepts of fair dealing
with information: the purpose of the Act is to give people access to
information about them that organisations are holding, NOT to force
organisations to change their practices so that they retain more
information than they otherwise would have (or to stop them from changing
procedures where these no longer seem to be sensible).
Richard Bunce
Senior Assistant Secretary (Corporate Services),
University of Hertfordshire, College Lane, Hatfield, AL10 9AB
DDI: +44 (0)1707 284904 Fax: +44 (0)1707 284918 Mob: 07762 061350
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