The people who provided their data for a statutory purpose and decided
not to provide their phone numbers, would have no expectation that the
organisation would then collect and presumably use their phone numbers,
so I doubt that this would be fair processing. To make it fair, the
organisation would need to tell people that it had their phone numbers,
and (depending on the use to which the numbers are being put) would have
to offer either an opt in or an opt out to telephone contact. If this
phone contact is for a purpose different from the original statutory
purpose for collecting the data, people would have to be told about this
too, and given an opportunity to opt in/out.
Susan Graham.
University Records Manager
Policy & Planning
University of Edinburgh
Old College
South Bridge
Edinburgh
EH8 9YL
Tel: 0131 6514 100
------------------------------------------------------------------------
--------------------------------
Date: Fri, 4 Aug 2006 12:03:56 +0100
From: Cathy Roach <[log in to unmask]>
Subject: A Friday Question?
Any thoughts on the following?
An organisation holds personal data (Name and Address) for a statutory
purp=
ose and now wants to append telephone numbers to this data by arranging
for=
a data supplier to match and append this information so that it can
contac=
t the individuals by phone. The organisation when collecting the
personal d=
ata initially allowed data subjects the option of supplying their
telephone=
number, but this was not a mandatory field.
Are there any issues with this and if so what would the
organisation/data s=
upplier need to do in order to comply with the relevant legislation?
Thanks for your help with this. Looking for thoughts on this for a paper
I =
am doing.
Thanks
Cathy
Cathy Roach
Assistant Compliance & Information Security Officer
Ipsos MORI
T +44 20 7347 3488
F +44 20 7347 3805
E [log in to unmask] <mailto:[log in to unmask]>=20
W www.ipsos-mori.com <blocked::http://www.ipsos-mori.com>=20
79-81 Borough Road, London, SE1 1FY
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