Chris
If the data subject is capable of being identified from the subset data
together with other information which is in your possession or is likely to
come into your possession then the subset data is personal data in your
hands and in the hands of your data processor. If not, then it is not
personal data.
Ian
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Chris Spray
Sent: 20 July 2004 11:51
To: [log in to unmask]
Subject: [data-protection] Data processors
If I hold personal data and have a subset, from which the identity of the
data subject cannot be established, processed by a data processor is the
subset still personal data and subject to the 7th principle requirements for
data processors, or, because it is anonymous to the processor, is it outside
the DPA in the processors hands?
I'm being advised the latter view is correct, but I'm not convinced!
Chris
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