Just to clarify, the activities would not take place in the leisure
centre, they are outdoor play schemes. The information would be paper
and transferred from the home to the place where the activity is taking
place.
We have started to look at the security measures of the external
company. And if we are not satisfied would certainly not pass the
information over.
The data contains sensitive personal data as it will relate to the
physical and mental health of the individuals. Explicit consent is the
only schedule 3 condition we can satisfy. Processing to an organization
of this type is not outlined (at present) in our fair processing
statement, in this section of work. As I understand the data subjects
have that right to be informed.
Once we have satisfied ourselves that there are more than adequate
security measures in place, we will look to implement an agreement which
will cover Principle 7 and Principle 5 issues. But I am wavering on
whether they would actually need the full care plan as requested or
whether it is better if they only receive the conditions, medication and
treatment information taking into account Principle 3).
Toby
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Bradshaw, Phillip
Sent: 23 July 2007 09:13
To: [log in to unmask]
Subject: Re: [data-protection] Passing personal data to third parties
which will then be stored at home
As an addendum to my earlier post I appreciate the question is in fact
one step removed. The principle remains that Toby needs to ensure that
the leisure centre has in place the controls described.
If they are not in place he should not be passing the data in the first
place - principle 7 again.
Phillip Bradshaw
Information Manager
Clerk to the Council
Room 111, County Hall
EMail: [log in to unmask]
Phone: 029 2087 3346
Mobile : 07779 284684
Fax: 029 2087 3349
Proactive Publishing Promotes Positive Perceptions
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Toby Davison
Sent: 23 July 2007 07:58
To: [log in to unmask]
Subject: [data-protection] Passing personal data to third parties which
will then be stored at home
Some of our young people with severe physical and learning disabilities
are going to take part in an activity scheme at a local leisure centre.
The leisure centre requires details from the care plans of these
individuals so that their needs are best met and so that they know the
conditions of them should there be an emergency.
None of these young people have the ability to act for themselves and
all of the parents have this responsibility. Consent has been sought and
achieved from the parents. It has now come to light that this
information will not be kept at the leisure centre but at the home of
the member of staff, where he mainly works. We have policies for our own
members of staff who need to take work home (although we do try to
discourage this) but not for situations like this.
We are in the process of informing the parents of this, and making the
leisure centre aware of their responsibilities towards this information
before allowing this to continue. Should we be seeking a more formal
agreement, which would take into account the security of this data?.
We would not want to hinder these activities because they will be
important for the young peoples well being and progress. Advice would be
appreciated.
Toby
Toby Davison
Archivist/Records Manager
The Together Trust
The Together Trust Centre
Schools hill
Cheadle
Cheshire SK8 1JE
0161 283 4815
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Registered in England 301722. Registered Charity 209782.
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