Ian,
I agree that this issue is direct marketing and in my scenario we are
definitely targeting a captive audience. The "Office Power" users are a
subset of the workforce (decreasing in number daily) not the entire
workforce so the material is being "directed to particular individuals".
The operation though is entirely automatic. The marketing message is
set up once on the server and is distributed to anyone who logs on. No
'apparent' use of personal data is made as the messages are sent to who
is logged on to the server - I suppose the argument of User ID as a
personal identifier would come into play! (Offices with generic user
ID's would get the same messages so I assume this would be ok?).
I will recommend that this facility is only used for work related
business and set up a "advertising" page on the Intranet for sale of
goods and services etc - I hope this solves the problem.
thanks all,
Lewis Bourne
Principal Information Security Officer
I.C.T. Services
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