I would have thought that an invitation of that sort was clearly
marketing and hence the "direct marketing" rules would apply. I would
also get seriously annoyed if someone tried to tell me in those
circumstances that the secondary use was compatible with the original
purpose.
Mind you, I'm still trying to get my head round a local authority doing
cashback on nappies !
Donald Henderson
Information Security Manager
Perth & Kinross Council
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Louise Widd
Sent: 19 August 2004 10:19
To: [log in to unmask]
Subject: [data-protection] DP - Nappies...direct marketing?
Hi!
I'm fairly new to data protection and after reading discussions from
the list for a few months I have a query of my own.
I've just had a phone call from one of our depts who have sent out
cashback forms to people using nappies. There was no indication on the
form that the peoples information (name and address) would be used for
any other reason other than getting cashback.
The dept now want to use the information to send these people an
invitation to an event where various nappy companies will be marketing
their goods.
My initial thought is 'direct marketing' but I'm not 100% sure on this
one....is the data that has been supplied personal in the first place?
and would it also breach Principle 2 if they used the info for that
purposes or would it be classed as being 'compatible with the original
purpose'?
Views please!!
Thanks,
Louise Widd
Compliance Assistant
Information Management Team
Chief Executive's Department
Leicestershire County Council
Tel: 0116 2658294
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