Paul Ticher suggested:
... an alternative approach might be to have a paper file recording complaints and outcomes, which is there to demonstrate that you have followed your procedures, but one that is not 'structured' so that you can readily find specific information about particular individuals (definitions in s.1) - i.e. perhaps it's just in date order. In this case the complaints log may well not be personal data. If it's not personal data, it's not covered by the Act, so is not available to subject access.
This to me looks like an evasion rather than an escape route. Is it a legitimate method for a public authority to keep information on people? There may be Human Rights Act implications to doing it. And how unstructured does a file have to be before it escapes? And if so, will it then have any valid use at all? If it's stored in date order, you have a way of relating the date to the individual and you can within a few minutes find the information relating to the case of the individual, isn't it structured enough? It seems to me likely that the reason Paula wants to keep it involves relating it to the individual.
Paul Hubert
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
If you wish to leave this list please send the command
leave data-protection to [log in to unmask]
All user commands can be found at : -
www.jiscmail.ac.uk/user-manual/summary-user-commands.htm
all commands go to [log in to unmask] not the list please!
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
|