Do I do I not have to notify?
As a Not For Profit (NFP) establishment the Information Commissioner's
Notification Exemptions self assessment guide provides me with a
contradiction. If I follow her flow chart through in a serial fashion
(as designed) I come across question 4 first, which asks if I carry out
any non-exempt processing. As my organisation trades or shares personal
information (why not personal data?) I am required to notify. I should
stop at this point and notify.
If I read on, I arrive at question 7, am I an NFP? Answering "yes"
leads me into question 8 where I look closely at the disclosures
question. Assuming my disclosures are with the consent of my members, I
arrive ultimately at the conclusion that I do NOT have to notify!
Was I wrong to go passed question 4?
In effect, does being an NFP place me above having to address non-exempt
processing?
Duncan S Smith
Principal Consultant
Mailto:[log in to unmask]
M: +44 (0)777 556 8180
T: +44 (0)1480 461 671
CoProfiles
"The Process of Improvement"
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