Phillip has a good point in that DP is also about the basics and using common personal information sense.  For example, in training I discuss whether it is acceptable to put a person's name in the subject line or their name and their medical condition.

If even if I had a need to know on both, they would still be bad from a dpa pov.

These may be common sense for dpa  but for many who are unaware of dpa it seems strange because it makes sense from an email efficiency pov it is conveying the info needed.

In the knitting example, you could put knitting hall charges in subject line and discuss the charges in the body without referring to anyone by name.  This would go a long way to durant and it would get officers to think of the transaction rather than the person.

Best

Lawrence


Lawrence
Lawrence W. Serewicz
Principal Information Management Officer
Room 4/140
Durham County Council
DH1 5UF
0191-372-8371


----- Original Message -----
From: This list is for those interested in Data Protection issues <[log in to unmask]>
To: [log in to unmask] <[log in to unmask]>
Sent: Sat Nov 06 10:30:25 2010
Subject: Re: [data-protection] SAR - Management Planning Exemption

In message
<[log in to unmask]>, at
10:10:48 on Sat, 6 Nov 2010, "Bradshaw, Phillip"
<[log in to unmask]> writes
 >>"What if the correspondence in question was about money owed by the
 >>ex-employee[1] to the organisation, and HR and Accounts were
 >>discussing what remedies they might have?"
>
>I am not saying I agree with Durant, compared with the Directive, but
>that seems precisely a Durant situation. The focus is on "what renedies
>do we have to deal with this issue" not on the data subject whose
>identity is irrelevant. They could have had the same discussion about
>"employee X".

They might have that generic discussion when deciding what to put in the
employment contract, but once an incident has arisen they may need to
discuss the specific details (amounts of money, length of default), to
see what form of action to take.

>As a side issue as a dp officer I try to avoid such issues arising by
>training managers not to identify staff when they report an incident or
>ask for advice. The rule is "if I need to know I will ask, until then
>keep it anonymous"

That's a good idea, but may not be practicable. Hypothetical example:
employee at a small school rents the hall in the evening (there's a
published tariff) and runs a knitting circle whose members are bad at
paying their subscriptions. Employee is late paying the rent to the
school. Difficult to anonymise if everyone knows only one employee ever
rents the hall.

 >>"And does it make a difference if the debt arose before or after his
 >>employment terminated?

 >Probably not.

Although one remedy, if the amounts were large enough and/or the debt
was contrary to policy, would be to initiate disciplinary processes that
might ultimately lead to dismissal.
--
Roland Perry

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