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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 Ian Welton
Sent: 24 March 2006 13:40
To: [log in to unmask]
Subject: [data-protection] Opt out lists
Are opt out lists held by organisations to prevent a data subject's data
being processed by that organisation available for enquiry using any of the
exemptions?
>>A SAR should deliver all such items to the data subject. The list must be
available at data take-on time to be queried against. Otherwise what do you
have in mind?
What if any restrictions exist to prevent fishing trips of those lists?
>>Policies and procedures must be in place including HR based sanctions to
outlaw such things
The reason for the enquiry is historically based upon a source for official
unease about opt out lists being that they would identify persons whom may
consider themselves to be at significant risk, and conducting data matching
exercises upon the lists could fairly easily identify those individuals.
>>Elizabeth France considered them to be a best Practice
Also, considered from the same risk angle, should security measures for
those lists be generally aligned with the original database security, or
should there be a higher level of security applied to them.
>>The level should be congruent with the data (or implied data) that they
contain
Ian W
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