I have a contract with a company, Iron Mountain, Pickfords etc. who
hold boxes of information for me. They have no idea what is in the box,
whether the data is personal, sensitive or neither. They just know
enough to know that I think the data is important enough to store. They
will at least be responsible for the Security of the boxes. This will I
think definitely make them data processors. Move this forward to TNT,
the Post office etc. Simply by putting something in an envelop I am
attaching a level of importance to it and a proportion of what I send
will be personal data. This might make the courier a data processor. By
taking responsibility for my letter in transit they may set themselves
up.
Chris Tinsley MSc
Wiltshire County Council
Information is the key
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of simon howarth
Sent: 02 April 2008 13:10
To: [log in to unmask]
Subject: Re: [data-protection] Status of postal/parcel services in terms
of DPA
I'm with paul on this one. I do not believe they are processing data
under the conditions listedin the DPA.
Even if they were, they would only be a processor.
Also, processing implies actually "doing" something with the data in
such a way that the data can be or is being accessed. If they don't open
and use the contents how can they be processing the data? Not only that
but could it even be deemed part of a relevant filing system?
I think the point is interesting to discuss, but ultimately an exercise
in philosophy.
Simon Howarth.
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