In a message dated 09/02/04 15:11:06 GMT Standard Time,
[log in to unmask] writes:
> We have been asked to remove a telephone number from all our records,
> relating to an individual.
>
> Certain departments do not have structured manual filing systems (i.e. it
> is not possible to access information about the individual without great
> effort)- is it reasonable to not comply?
>
> If this individual should contact us in future and leave a telephone
> number as means of contact can we still record this?
>
> We also feel a duty to our staff to protect them from this individual, and
> the only means of identifying them has been the telephone number in the
> past, can we therefore retain the number?
--------
If the only condition under Schedule 2 that can be met for holding the phone
number is consent, then that consent has been withdrawn. If another valid
reason exists (I assume that would be possible but unlikely as we can all go
ex-directory) then you may be able to keep it.
You would not necessarily have to look though manual files that are
structured, because it would be unlikely the number would be accessed or used. The
staff who are likely to contact the person can be told "don't call him/her by
phone, don't look up his/her number".
If he/she leaves a number in future it would be for one particular
transaction unless they state otherwise and would have to be deleted asap afterwards.
I can't see how a phone number can be used to identify someone to protect
staff - can you please expand on this and explain how this works?
Ian B
Ian S Buckland
Managing Director
Keep I.T. Legal Ltd
Reg: 3822335
T: 01246 473999
F: 01246 470742
E: [log in to unmask]
W: www.keepitlegal.co.uk
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