This is always difficult.
My preference would be to give a definition - in nice simple terms - if such
exists for 1(1)(e) (!) - accompanied by some solid examples. As there
aren't that many (?) - are there any? - the examples should be pretty
meaningful.
The other approach would be to ignore it altogether - especially if there
aren't any current, widespread, examples.
David Bownes
Data Protection and Security Officer, Sheffield City Council, Chief
Executive's Directorate, Corporate Resources, PO Box 1283, Sheffield S1 1UJ.
Tel: 0114 2736891 FAX: 0114 2735576
-----Original Message-----
From: Paul Dodgson [mailto:[log in to unmask]]
Sent: 11 December 2006 13:44
To: [log in to unmask]
Subject: [data-protection] The obligations about unstructured personal
data
Hi,
I am doing a little work on DPA, revising our policy actually.
It has not been revised for far too long. I have been reviewing the
changes brought about by FOI (Section 68, 69 and 70)
I am trying to construct an understandable set of content.
The new Section 1(1) (e) - recorded information not covered by (a) to
(d) is where I am looking to put together something simple.
Can I please ask you to help me in doing a reality check, my new
statement (for non DPA kinda folk!) in the policy will read something
like
"unstructured personal data falling within 1 (1)(e) of the Data
Protection Act 1998 does not have to be disclosed if it falls outside of
the 18 hours FOI rule. Please seek advice from the Council's Compliance
Manager should you believe any subject access request meets this
criteria".
I fear this is too simple, but seek your views.
Regards
Paul
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