That aside if you use the number (whether owned by them or not) are you
not invading their privacy against their expressed wishes.
Jane Holden
Corporate Services Officer
Legal Services
Barrow-in-Furness Borough Council
Town Hall, Duke Street
Barrow-in-Furness
Cumbria LA14 2LD
Tel: 01229 876452
Fax: 01229 876515
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Griffiths, Ian
Sent: 15 March 2011 15:00
To: [log in to unmask]
Subject: Re: [data-protection] CLI
Do they need to own the line for it to be their data?
Ian
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Donald Henderson
Sent: 15 March 2011 14:56
To: [log in to unmask]
Subject: Re: [data-protection] CLI
Sorry to disagree, but everyone is making the assumption that the CLI
number is the person's phone number. From what has been said, all you
actually know is that it is the number the person phoned from, but you
don't actually know their phone number.
So, as it stands, the CLI might be someone's personal data, but you
don't know whose. And using it for handling the complaint would be
stupid (especially as the person has said no contact by phone).
Donald Henderson
Information Compliance Manager
Perth and Kinross Council
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Griffiths, Ian
Sent: 15 March 2011 14:43
To: [log in to unmask]
Subject: Re: [data-protection] CLI
At a guess -
1. Yes, consent has been revoked and no exemption has yet been
established.
2. Can you legitimately argue this?
3. Difficult to justify.
4. Perhaps!
Ian
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Phil Bradshaw
Sent: 15 March 2011 14:23
To: [log in to unmask]
Subject: [data-protection] CLI
Customer service centre recieves a complaint by phone. Complainant
provides address for a written response but declines to provide a phone
number when requested as does not want further contact by phone.
CRM system automatically takes and records the phone number from the
incoming CLI data.
1. Is this a dp breach per se? or
2. Is it only a dp breach if we access and use the number for the
purposes of handling the complaint, but not if we only use it for
'management purposes' - I cannot actually think of any but you never
know ...? or
3. Not a dp breach at all as customer could have blocked CLI and by not
doing so we have implied consent to use it as long as not an
incomaptible purpose.?
4. Something else.
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