I now have had very prompt feedback form the ICO's Office in Wales on the
issue of the apparent lack of necessity for a Schedule 3 condition.
The point they are stressing is that a Schedule 3 condition has to be
applied, including any condition under the Sensitive Data Order. They
realise that there may not be a best fit for that Schedule 3 condition and
hence will deal sympathetically with any subsequent complaint.
There is also a hint of a softening of the interpretation of the 'vital
interests'. I have had a fairly long discussion on the subject of assessing
risk, out of which it still appears that it is a matter of judgement.
Mike
------ Forwarded Message
From: "Lloyd M J B (ISeLS)" <[log in to unmask]>
Reply-To: "Lloyd M J B (ISeLS)" <[log in to unmask]>
Date: Thu, 25 Jan 2007 14:25:46 +0000
To: <[log in to unmask]>
Conversation: New guidance from ICO - working with potentially violent
members of the public
Subject: Re: New guidance from ICO - working with potentially violent
members of the public
I have contacted the ICO's office in Wales on this guidance note and they
are going to look into it further.
I will pass on any information I get to the list.
Mike
------ End of Forwarded Message
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