I think this expresses very well the concept I was unsuccessfully
grasping at. If you are a bank, as a matter of opinion, I think it is
REASONABLE for you to ask for my passport/ID card as you have those
already (or data of similar sensitity) by the operation of statutory
rules (I.e anti-money laundering) (However, askin for these by post
STILL does not stop id theft!!). If I make an SAR on a company or
organisation like a spammer which SHOULD have no data, or marginal data
about me, then sending such data is UNREASONABLE (again, IMO).
Whether something is reasonable or not, is often irrelevant.
The question is what is LAWFUL??
I have yet to find the relevant section of the Act. (Can anyone direct
me to it?). But I seem to recall the expression "sufficient to identify"
being bandied about.
This is a LONG way from "*prove* your identity". It is not the same at all.
I submit that name and address is normally "sufficient to identify" me
in most circumstances. (Where you the data are stored agaisnt a previous
address, then that address is would be required to be sufficient.)
Ultimately it is a matter of construction and you can't decide on
'gut-feel' unless the word 'reasonably' appears in the law. You have to
apply statutory interpretation to the relevant section.
Anyone able to quote chapter and verse?
Regards
Tony Bowden wrote:
> On Mon, Oct 30, 2006 at 04:28:57PM -0000, Tim Trent wrote:
>
>>Since people worry about ID Theft, I think it is valid to ask for serious
>>ID, even for "trivial" details. This is for our protection as much as
>>theirs.
>>The more private the data the more security we need to deploy.
>
>
> I think a good rule of thumb is that you should not be requesting any
> form that ID that provides any data that you don't already (legitimately)
> hold on the data subject.
>
> i.e. proving identity should not involve revealing more information
> than would already be known.
>
> Tony
>
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Nigel Roberts BSc CEng FBCS DipEngLaw, Director
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