I've just had a phone call from one of our depts who have sent out cashback
forms to people using nappies. There was no indication on the form that the
peoples information (name and address) would be used for any other reason
other than getting cashback.
>>The purpose for which the data was collected is solely cashback
The dept now want to use the information to send these people an invitation
to an event where various nappy companies will be marketing their goods.
>>Lack of forethought. They can ask for further permissions from them, of
course, but technically not market to them without that permission having
been given. But, as with all such things, the commercial risk should be
balanced against the commercial gain. The UKIC is at best slow in enforcing
the law, the Spanish equivalent is a cross between Jaws and a Rottweiler.
My initial thought is 'direct marketing' but I'm not 100% sure on this
one....is the data that has been supplied personal in the first place? and
would it also breach Principle 2 if they used the info for that purposes or
would it be classed as being 'compatible with the original purpose'?
>>Personal, yes. Otherwise they could not be contacted :). To me the
purpose of collection and the new processing concept are entirely divorced.
The word "oops!" comes to mind
Views please!!
Thanks,
Louise Widd
Compliance Assistant
Information Management Team
Chief Executive's Department
Leicestershire County Council
Tel: 0116 2658294
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