Duncan,
I'm not a lawyer, so if we are arguing at that level of detail then we'd
have to employ lawyers to settle it. From a NFP perspective or that of any
other public body we don't want to be in that position. It costs too much.
It's not the simplest or safest route in my opinion, it's the only route. We
can't afford to be martyrs.
I view the Commissioner's advice as the equivalent of the Highway Code.
Ignore it and you risk prosecution. Her advice is that 'Trading/sharing in
personal information' (The sale, hire or exchange of personal information)
and the other purposes listed in Q4 of the 'Notifications Exemptions Self
Assessment Guide are non-exempt purposes. I notify on that basis.
Allan
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