If the data is sufficiently inaccurate and does not uniquely indentify
one individual then there it is my feeling that there are no problems
with data protection.
Merely dropping the last two characters would be sufficient to do this,
where L3 5TP becomes L3 5. While the former relates to one address
only, the latter extends to many more. The point that this data is then
not accurate enough I disagree with. These people whose position is
rounded to the nearest post sector are still close enough to car-share.
Furthermore you don't actually need people to live close to share a car
to work, in fact there are some successful arrangements currently in
action with my current employer in which the car owner passes the house
of their passenger, who they collect en route. Clearly postcode
analysis would not have identified this possibility. This means they
always use the same car of course, which is not really how it works, but
everyone is happy enough.
You then of course would introduce a data protection issue when you
actually tried to make it work as all of the analysis is useless unless
people actually want to do it. At which time you have to ask them,
which means you have to have identified them.
Personally I would be advertising the scheme with the usual means and
when I had enough people, perhaps drawing a few maps to get a rough idea
of what was going on, but nothing too accurate. The road network,
interpersonal issues and journey times introduce far too much complexity
to just call this a data issue alone.
Whether you choose to do this via payslips or other means (intranet?
dare I say it - notice boards?!) is entirely the choice of your
organisation based upon the expectation of your staff. I'm sure it is
not unreasonable for an employer to communicate with their staff via
payslips. My employer certainly do.
Ian
-----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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