Are you joint data controllers? I would presume so and you should have
notified as such.
If indeed you are joint data controllers then the requestor would only
need to make one SAR.
Doreen
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Mandi Barron
Sent: 05 October 2005 15:32
To: [log in to unmask]
Subject: Who holds the info
All
We have students based at a Partner College. The students are registered
both as students at the University and at the College. All student files
are held by the College, but we hold information about exam board
results and student marks. I have received an SAR from a student wanting
all personal information that we hold. In this instance is the College
acting as a Data Processor on our behalf and therefore is the provision
of the student file our responsibility, or should the student make a
separate SAR to the College. I can see the logic of both arguments and
am stuck! Grateful for any helpful advice.
Mandi
Mandi Barron
Assistant Registrar (Regulation) and Information Officer
Bournemouth University, Registry
HR108, Heron House, 10 Christchurch Road
Bournemouth, BH1 3NA
tel: +44 (0) 1202 964783 fax: +44 (0) 1202 963869
email: [log in to unmask]
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