I thought we had managed to beat this subject to death and then another
thought comes to mind. Maybe e-mails are only personal data if they are used
in the wrong context. I hold e-mail addresses in my Outlook Contact List
because people have been in touch with me or I have been in touch with them.
Sometimes I have trolled through a web site to find the contact I need - the
name of the manager of the person who is supposed to fix the street lamps. I
doubt if holding them on this basis is a breach of DPA even if I am not
registered as a data controller and my business use is so light as to not
require registration. However if I was to use that list for some dodgy
purpose such as selling DPA registration services the information would
probably be considered personal and my usage would also contravene the
recent Privacy and Electronic Communications (EC Directive) Regulations
2003.
So that's my conclusion - Yes or No depending on usage.
David Aspinall
Datum Solutions Limited
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