Not forgetting Newham Borough Council too....they kept for 7 years and
used for a completely unassociated purpose.........which cost them
dearly!!!
Doreen
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Tim Trent
Sent: 21 July 2005 11:52
To: [log in to unmask]
Subject: Re: Photographs and retention
In general these matters depend on what is "reasonable". The "belief"
held by the marketing staff is not from any documented "reasonableness"
though it is not unreasonable.
What you need is a set of policies detailing classes of data and
retention periods for all data that falls within the scope of
legislation that requires or allows retention. IN addition the other
side of the pancake is
required: Deletion policies and destruction policies. The two sound
similar, but are not.
Where there is no formal legislative retention period (such as
accounting
data) it is up to you to set and to be prepared to back the setting of
your own retention periods. It is fair to invent your own standards for
reasonable retention periods provided you have a rationale for doing so.
With photographs the "personal nature" seems to depend upon the crowd
size.
My picture solo is personal data. My pic in a group of two or three is
personal data for each of us. At what point does it turn into a crowd
and become "depersonalised"?
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 http://www.marketingimprovement.com
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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 datap
Sent: 21 July 2005 11:45
To: [log in to unmask]
Subject: [data-protection] Photographs and retention
Hello all,
I have just spent a large portion of the morning searching the archives
and I am fairly sure that this has not been covered, but apologies if I
am mistaken!
I was wondering if anyone knew of any legislation governing how long we
can keep photographs for marketing purpose? I.e. we take photos of
customers at a public event, get a consent form for use of that
photograph in publicity material / internet etc, but how long can we
keep that photo and reuse it for (consent aside)? Our marketing staff
believe it is two years but cannot say where this figure comes from.
I thank you all in advance.
Best regards,
Tanya Holden
Information Governance Manager
Metropolitan Housing Partnership
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