Areas where there is a virtual partnership are always complex. The answer
depends on what personal data is held and by whom.
If the DAT holds data in it own right then it requires notification in its
own right.
If the DAT need not notify, but the bodies forming the virtual partnership
pass data to each other and are themselves the legitimate data controller or
the data, then the fact of the data being passed to other members (current
and future) of the DAT has to be permitted by the Data Subject.
There could end up being sufficient permutations of this to bewilder,
because permission is needed in order to pass data anyway, and the data is
likely to be sensitive data, especially where (eg) the Probation Service is
included in the DAT
Logic says "Notify AND get permissions to pass data. Belt and Braces".
Where there is scope for confusion, pay £35 and have done with it.
Tim Trent - Consultant
Direct: +44(0)1344 392644 Mobile:+44(0)7710 126618
email: [log in to unmask]
Marketing Improvement Limited, Abbey House, Grenville Place, Bracknell,
United Kingdom, RG12 1BP
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-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Adam Warren
Sent: 16 May 2005 09:10
To: [log in to unmask]
Subject: Re: [data-protection] DATs - registration
Sorry, DATs are Drug Action Teams.
There appears to be some confusion whether, as 'virtual' partnerships, with
staff employed by Social Services, Primary Care Trusts, drugs charities etc
they require registration under the DPA.
Best wishes
A
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