Well good morning all !
Although I know that it feels an hour earlier than it is (my baby is yet to
understand the BST thing) I have an interesting fact, Friday evening whilst
being dragged around shopping by my wife I came across the CCTV notice used
by ASDA Stores. Does the sign comply with the Commissioners recommendations
in size, NO. Does the sign display an image of a camera, NO. Is the purpose
of the cameras processing clear, ERRM not really the notice actually states
that "CCTV used in this store to help keep prices low".
How are prices going to be kept low by having a camera recording the goods,
is it in case the price gremlins climb out from behind the bread and change
the price displayed??? Seriously (for a moment) checking the commissioner's
website the cameras are notified for Purpose 16 - Method 2, basically crime
prevention/detection for the recording of sound and/or visual images.
Another worrying aspect is that all the processes notified by ASDA have a
transfer inclusion of the USA, although this may be understandable for
certain details due to ASDA's mother company being Wal-Mart should this
include the recording of visual images of shoppers. I doubt Wal-Mart have
signed upto the "safe harbour agreement", so once the tapes are in the US
what protection do I have as an ASDA shopper?? Could I soon see myself on a
tacky CCTV show in the US showing how picky red headed brits are when
choosing their bread?
Answers on a postcard
Paul Couldrey
Data Protection Officer
Wolverhampton City Council
-----Original Message-----
From: Eagle, Dave [mailto:[log in to unmask]]
Sent: 20 March 2001 14:00
To: [log in to unmask]
Subject: Re: Disproportionate Effort!!!
Hi,
'Getting subject in and showing them the data should cover you' is a
statement which chills me to the bone.
What if they can't easily get in without disproportionate effort on their
part - e.g. travelling 300 miles?
What if they can only get in after 9.00 pm or at weekends?
What if it just isn't convenient for them to come in at all?
What if they don't want to examine the data with someone looking over their
shoulder?
How long do you allow them to examine the data for when they do come in?
Relying on Data Subjects to come in to see their data is obviously not going
to work in many cases. I can't see anything in the Act which will allow a
Data Controller to use this as a way of avoiding making time-consuming and
expensive copies.
Accept that sometimes (most times?) copies will have to be provided and
design your internal systems around this. And remember, we are all Data
Subjects too.
Dave Eagle.
Community Informatics Research and Applications Unit.
-----Original Message-----
From: Peter Wilson [mailto:[log in to unmask]]
Sent: Monday, March 19, 2001 3:49 PM
To: [log in to unmask]
Subject: Re: Disproportionate Effort!!!
Paul,
1. You still have to process the SAR. Getting subject in and showing them
the data should cover you.
2. Would be interested in which section your colleagues would use as a
defence! Some LGA's do use a SAR form with tick boxes for areas of
particular relevance to the subject. This is not a legal requirement but can
be helpful in reducing open-ended requests.
Peter
Peter Wilson
Data Protection Officer
University of Paisley
>>> Paul Couldrey <[log in to unmask]> 03/19/01 02:31pm >>>
Good Afternoon
Thanks to all those that responded given me an alternative product to easy
i. The next question is two fold really it has came about by statements
that I ghave heard made by other DP officers.
1. Disproportionate Effort is often used as a reason for not complying with
a data subject request, however I though that section 7(1)(c0 only refers to
the fact of supplying the data in a permanent form, NOT to stop a request,
any thoughts?
2. Open ended requests are often refused by collegues of mine i.e. "supply
me with all the data the council holds on me". If people are using this as
a defence not to conduct a SAR what areas of the act are they relying upon?
Any help?
Paul Couldrey
Wolverhampton City Council
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