I went through the postcode issue many years ago.
You have to remember that any data that can be further matched to identify
an individual is personal data. Now in a lot of instances identification of
a single person from a postcode is hard enough to make you think that it is
not personal data. However I can give you one example where a postcode
covers three dwellings. Now it becomes much easier to match an individual as
the number of people are reduced. It becomes even easier to match when you
find that two dwellings contain couples over 60 and the third a couple under
35. you now only need ages to start to be able to home in on an individual.
You need to consider how the postcode will be used, maybe think about asking
staff to consent to having their postcode shared?
You are right on the first part of the postcode, it won't be specific
enough. Maybe the first digit of the second part of the postcode would help?
I would err on the side of caution, but would also be very interested in
what the ICO has to say on this matter as some water has gone under the
bridge since I last looked at this in isolation.
Simon Howarth.
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Caroline Dominey
Sent: 26 February 2007 09:11
To: [log in to unmask]
Subject: [data-protection] Are Post Codes Personal Data?
Good Morning,
I have already posted this to another list but would appreciate any
further thoughts.
We have received a request for a list of full postcodes for the home
addresses of all members of staff to promote a local carshare scheme (no
names would be attached to the postcodes). I do not feel that we should
release this information, because although one postcode could cover a
number of houses you may have the odd case where someone lives in the
middle of nowhere and the postcode relates to them only. (I have suggested
we release the first part of post codes only, but have been told this
would not provide enough information).
However, it is being argued that postcodes are not personal data, and I am
aware that other organisations have released the information. I would
appreciate any advice/comments on this.
Many thanks
Caroline
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