Not sure that Steve's original question needs such in-depth analysis of DP
implications! If CTR just intend auditing a random sample to compare total
number of adult occupants unlikely to be "personal data" - e.g. the CTR
only has 1 adult being assesed for council tax but the ER has 3 adults
registered to vote.
At which point presumably CTR will want to know more details of the other 2
adults from ER - because may want to prosecute for fraud if occupant
claiming 25% tax relief.
But the person responsible for compiling CTR can require information from a
number of sources, including electoral roll, under the Local Governement
Finance Act 1992 & subordinate regulations.
Also the ER officer has the right to inspect & copy any records held by the
council that employs him / her under the Representation of the Peoples Act
2000 & subordinate regulations.
Think the ICO guidance suggested that names & addresses & dates of birth
would be acceptable but any other information requested would have to be
subject to 'normal' non-disclosure considerations ?
Regards, Kirsty.
Kirsty E Gray
Data Protection Officer
Commission for Social Care Inspection
Note: comments for discussion and debate only and do not necessarily
reflect the corporate position of the CSCI nor constitute legal advice.
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