The purpose for processing library client details is lawful and the ICO
notification no doubt reflects that for each of the authorities
involved. However, the borrowers must be informed that their details
may be available to the other two authorities and be given the
opportunity to opt out, or at least not have their data accessed by the
other authorities. You also need to be sure that the other authorities
are taking adequate steps to comply with the 8 principles while they
have access to your borrowers' details.
My view, therefore, is that a data sharing protocol is required which
each authority needs to sign up to, and which details the lawful basis
for sharing and the arrangements in place to manage and protect the
data.
Julie Gibbs
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Brenda Scourfield
Sent: 17 July 2006 11:36
To: [log in to unmask]
Subject: [data-protection] Sharing data
Three local authorities are considering purchasing together a library
system to hold lenders details. There will be one big database holding
the
personal data. Whilst each authority will have its own records, the data
would in theory be available to all. Is there a need to set up a data
sharing protocol or as the purpose would be the same ie lending of
books/cds/dvds etc would this not be required.
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