I have picked up an issue which is going round one of our departments and I
would really like any comments about the validity of their proposal:
They are suggesting that (to avoid having to gain consent to disclose from
third parties each time a subject access request is received) a general
statement should be added to emails, letters and memos to say that, unless
the recipient states otherwise, the department may share information the
third party provides about a service user, with the service user.
I have many reservations about this. For instance:
We do not automatically have to contact all third parties for consent if the
disclosure is reasonable.
Situations can change
It would be very wrong to put the decision entirely onto the third party.
Any help very gratefully received.
Sophie Houlton
Somerset County Council
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