-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Mark Harris
Sent: Friday, February 22, 2002 9:45 AM
To: [log in to unmask]
Subject: Re: Payslip Advertising
"My organisation is a university. It recognises two trade unions: AUT
and Unison. The unions have asked whether they could advertise on the
payslips. The nature of the advertisement would be to inform staff that
they have the right to join one of these unions and to give (with
permission) a contact name and phone number.
What would be the position in this scenario?"
This is host mailing, their status as Unions makes no difference so it
would be direct marketing. This means you have to abide by any Section
11 opt-outs (process in accordance with the data subject's rights) AND
ensure that you are not processing beyond the original purpose for which
the data was obtained. Given that this is payslip data, it is unlikely
that employees were fairly informed about such uses of data when they
joined (or subsequently); breach of Principle 2.
Yulli's comment about not segmenting/targeting individuals is an
interesting debate, as this could define the action as advertising not
direct marketing? I for one would not fancy my chances at a tribunal on
those grounds, but this question invariably causes long debates in the
course I run.
By the way, a host mailing is deemed as Trading in personal data even if
no financial reward is made - make sure you are notified accordingly.
Duncan S Smith
Principal Consultant
e-mail: [log in to unmask]
gsm: +44 (0)777 556 8180
Company Profiles
"The process of Improvement"
----------------------------------------------------------------
The information transmitted is intended only for the person or entity to
which it is addressed and may contain confidential and/or privileged
material. Any review, retransmission, dissemination or other use of, or
taking of any action in reliance upon, this information by persons or
entities other than the intended recipient is prohibited. If you
received this in error, please contact the sender and delete the
material from any computer.
This footnote confirms that this email message has been swept by Norton
Antivirus software for the presence of computer viruses.
Company Profiles Huntingdon UK +44(0)1480 461671
-----------------------------------------------------------------
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
All archives of messages are stored permanently and are
available to the world wide web community at large at
http://www.jiscmail.ac.uk/lists/data-protection.html
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)
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
|