Doreen,
Housing records are classed as 'accessible records' in Schedule 12 of the
Act. This means that they don't have to be in a 'relevant filing system' and
basically, subject access includes all information including manual records,
continuing the access that was previously available under the repealed
'Access to Personal Files Act 1987'. As before, the information accessible
is all information held for the purpose of the tenancy in respect of a
current or past tenancy or housing application.
Allan
-----Original Message-----
From: Broom, Doreen [mailto:[log in to unmask]]
Sent: Tuesday, 22 May 2001 14:37
To: [log in to unmask]
Subject: Relevant Filing System
All
The Act states "or by reference to criteria relating to individuals".
My question is - we have council tenants - we hold files and some files
contain information about all previous tenants (probably an unstructured
file) with only the address as the identifier on the front of the file. If
a subject access request was made would be have to go to that file as the
contents of the file could hold information relating to them while they had
the tenancy, albeit it would not be a current address and therefore the
information would not be accurate or would we only have to go to that file
if the data subject expressly asked for all information relating to him/her
and included all previous addresses?
Any help would be appreciated.
Doreen Broom
Data Administrator
Scottish Borders Council
Council HQ
Newtown St.Boswells
Melrose
Borders TD6 0SA
Tel: 01835 824000
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