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Ah, it's too difficult so we wont do it!
Not sure I would want this as my defence in court.
Simply browsing a web site (cookies 'n all) is unlikely to cause much of a
problem, as this data is mostly anonymous i.e. not personal data. But once
we start to identify an individual (forms, Amazon style log-ins etc) this
data is personal.
To significantly change the use (purpose) of data processing and promulgate
this in a (potentially unread) privacy statement has to be unfair
processing (as in TTT!)
The only logical way of staying compliant is therefore to instigate a
positive response return device to prove that your data subject has read,
understood and agreed to your changes (read-receipt would not cut it, as it
only indicates read, not read and understood).
Funnily enough, I have yet to see anyone doing this!
Regards,
Duncan
Managing Director
iCompli Limited Northampton UK
T: 08707 70 48 66 F: 08707 70 48 69 M: 07775 56 81 80
Mailto:[log in to unmask] Web: www.icompli.co.uk
"Compliance in your language"
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