In a message dated 02/02/2001 16:29:24 GMT Standard Time,
[log in to unmask] writes:
<< As part of their Community Education projects, the Council I work for fund
a
number of community and youth organisations that provide services on their
behalf. They therefore hold personal information about clients (young
people) both for their own use and because they are required to report to
the Council, who then in turn report to the Government.
Can we consider those community organisations data processors or are they
separate data controllers ?
Would anybody have an idea on this ? >>
------------------
Karine
If the organisations have the data "for their own use", then they are,
without doubt, data controllers. If the only data they give the council is
for justification of the funding (as I suspect) then the council is a
recipient and would be described as such on the organisation's notification
entry. If the data given to the council are more than just the numbers of
clients, and personal data are included, the council must also register the
purposes for which they use the information (finance, grants, reporting to
government, etc).
By the way - if the council processes staff records for these organisations
the council is the data processor (not the controller) and the community
organisation will need to register payroll / personnel as well.
Ian Buckland
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