Very interesting article about this in the Law Society Gazette yesterday,
which suggested that money-laundering suspicions raised within an
organisation could be subject to disclosure in a SAR. Only once reported to
NCIS, might there be some S.29 exemption. Concerns raised about possible
tipping-off as well.
The link is http://www.lawgazette.co.uk/articles/2.asp
regards
Su
Su Goulding
Data Protection Analyst
tel: 020 7330 3491
mobile: 07767 674376
[log in to unmask]
-----Original Message-----
From: Clare Bond [mailto:[log in to unmask]]
Sent: Tuesday, January 29, 2002 2:11 PM
To: [log in to unmask]
Subject: Data Subject Access Requests & Police Referrals
Please can you tell me what your thoughts are on the following scenario.
If we receive a Data Subject Access Request from an individual who we
believe has some involvement in a Money Laundering offence and by releasing
the information this might reveal a referral to the Police or NCIS, what
should we do?
There appears to be a conflict between the two acts (Money Laundering & Data
Protection Act).
I would appreciate your comments on this type of situation.
Thank you,
Clare
Clare Bond
Compliance Officer
3rd Floor, Ladymead
Tel: 01483 55 2944
Fax: 01483 55 2946
Email: [log in to unmask]
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