Under section Sch 1, 2(1) Fair Processing code data controllers are required to issue, data subjects with a statement (fair collection notice) informing them of details as set out in para 3.
Whilst I understand this requirement can anyone confirm the action to take in the following circumstances to comply with the code:
a) manual personal data held within a relevant filing system and processed prior to oct 1998? Do I need to issue an FCN to these data subjects?
b) automated personal data held and processed prior to oct 1998? Do I need to issue an FCN to these data subjects?
c) manual personal data collected after Oct 1998 and still being processed? Do I need to issue an FCN to these data subjects?
d) automated personal data collected after oct 1998 and still being processed? Do I need to issue an FCN to these data subjects?
e) automated data collected after March 2000 and still being processed? Do I need to issue an FCN to these data subjects?
f) manual data collected after march 2000 and still being processed? Do I need to issue an FCN to these data subjects?
The personal data is a mixture of "data" and "sensitive data"?
--
Julie Burcham
Managing Consultant
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