>dark rain clouds seem to be coming in from Derbyshire.
Nice to see the generous nature of my home county has not diminished over
the years.
The only "blanket" privacy policy we have is the one on our web site. The
site was initially information only and the privacy policy of the time
reflected that. When it was subsequently changed to enable on-line services
the policy was updated. On each occasion our solicitors were involved to
ensure compliance with legal requirements. We do reserve the right to
change the policy and users are advised to review the page regularly to
keep abreast of any changes.
Having said that, the "blanket" privacy policy is a general, overarching
one. Each form associated with an on-line service is accompanied - as it
should be - by a specific statement of who will have access to the
information and what it will be used for.
In terms of traditional service delivery, statements describing how data
will be processed are provided whenever data are gathered. An easy example
is the statement on a housing benefit renewal form. In areas such as Social
Services, officers receive specific advice to check with service users
whether existing consents (or otherwise) are still valid. This is
especially the case where the practitioner may have reason to suspect that
circumstances have changed - better to pro-actively check than just to
assume that service users know they have the right to change their mind.
Where we make changes to wording on forms I point out to the managers
concerned that, if the necessity should arise, they must check which
version was in existence when the data subject completed the form and
proceed accordingly to ensure that their actions reflect what the data
subject would expect.
Regards,
Graham
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