Paula
Some thoughts
1: You state that it is a 'staff' telephone directory. In so far as the
employee records you can argue the 'new' activity as part as the same
purpose the payroll data is notified under ie Staff administration. The
purpose description includes ''other personnel matters in relation to the
staff of the data controller'' Look at the dictionary definition of the
word personnel and you'll see the wide scope this purpose.
2: Are not staff notified at recruitment that information will be processed
by the data controller (the employer) for staff administration purposes with
the other consituents parts of a fair obtaining notice. If so no additional
notice of use has to be delivered. However if they were only advised payroll
uses a further notice is arguable given the first use was narrower than it
needed to be in relation to the purpose you may notify on a DP notification.
3: No consents required as the data set does not appear sensitive. Sch 2
legitimate interests works.
Hope this assists
David Wyatt
----- Original Message -----
From: "Paula Leon" <[log in to unmask]>
To: <[log in to unmask]>
Sent: Wednesday, March 05, 2003 12:35 PM
Subject: [data-protection] subsequent use of data
Dear folks,
Have a dilemma, that you may lend your views to.
We are currently revamping our existing staff telephone directory and would
like it to interface with our new system (SAP) to be up and running for
April. The key link we want to use for the interface between each system is
the most useful identifier the "Payroll " number.
The telephone directory will not display any additional information than it
currently does, but will have advance features installed for ease of use, eg
more varied ways of searching.
The payroll number will strictly be used for interfacing and this number
will NOT appear anywhere on the views to staff. The interface will only
download the information needed specifically for the directory, eg name,
location, extension number, job title.
Because I want to use the payroll number for this reason, am I obligated to
tell the staff, though they will not see any personnel details or anything
different that what they have previously seen in the staff directory. Would
this be a DP issue.????
Details on the SAP system will only be able to be viewed by authorised
personnel staff, as they currently did in the old system.
any useful advise, gratefully received.
Paula
Paula E Leon
London Borough of Waltham Forest
Corporate Services Directorate
e-Goverment Services, ICT Unit
Town Hall, Forest Road
London E17 4JA
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