My view is that the academic is the responsible person, the Data Controller,
within the association. The association must make correct registrations,
and it is the joint and several responsibility of the academic and the
association to make a new entry when a new data controller is appointed.
The university must also be AWARE of the existence of the database, and must
have a suitable declaration of data use registered with the Data Protection
office in order to ensure that THEY do not fall foul of any investigation
into data misuse.
_____________________________________________________________
Tim Trent
Chief Privacy Officer EMEA
Gartner
EMEA Marketing, Tamesis, The Glanty, Egham, Surrey, United Kingdom,
TW20 9AW
Switchboard +44 (0)1784 431 611, Direct Line +44 (0)1784 267 335, Mobile
+44 (0)7710 126 618
Visit our home on the web: http://www.gartner.com
Please note that my direct line has changed to +44 (0)1784 267 335.
Please update your records to reflect this.
-----Original Message-----
From: Data Protection Officer [mailto:[log in to unmask]]
Sent: 13 August 2001 12:26
To: [log in to unmask]
Subject: Professional Associations - Honorary Officers - Databases -
Whose is what?
Hi,
Background: An academic becomes the honarary secretary of a professional
Association. The academic wants to build up a database of members [including
potential members] of the Association. The database will be
installed/maintained on University equipment as long as the acedemic both
remains the honorary secretary and remains employed at the University -
after that, it will presumably be passed on to the next honorary secretary
or the next University.
Question(s):
1 Who in DP terms owns, and is responsible for, the data base? The
University, the Association, the academic, or both or all of them? My guess
is te Association.
2 Presumably the academic could be considered as the data controller?
Or is he the data processor?
3 Is the University, and the honorary secretary, just the data
processor with the Association as the data controller?
4 Is it the Association that registers the database?
Any advice/comments appreciated.
David.
----------------------------------------
David Fildes
Data Protection Officer
Room 650
Gilbert Scott Building
University of Glasgow
Glasgow
G12 8QQ
tel: (0141) 330 5146/3111
fax: (0141) 330 4920
<http://www.gla.ac.uk/dataprotection/>
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