Brenda,
I agree that you have to be careful with a PVP, however, the DPA (nor the FOIA) does not distinguish applicants (to that granularity). If you are worried about HnS of the officer, then there would be grounds to consider. However, a PVP could be someone who shouted in the lobby over the injustice of the Council Tax system. (See for example the Slough case), which means that the need to redact has to be proportionate and sustainable in similar cases.
In Durham, we have a tragic history regarding the PVP issue so there is a certain organisational sensitivity here to that issue.
If the PVP does send an abusive email, then the officer can use that as evidence in court with which to seek legal and organisational redress. Sometimes these issues have to unfold before more robust action can be taken. Having said that, the nature of the PVP needs to be considered closely so that the threat of an abusive email never materialises because the PVP escalates to physical violence.
If you redact, you will need to have a good argument that is justifiable to the PVP as well as to the ICO if there is an appeal.
Best,
Lawrence
Principal Information Management Officer
Durham County Council
Room 4/140
County Hall
County Durham
DH1 5UF
0191 372 8371
VPN 77778371
-----Original Message-----
From: Scourfield, Brenda [mailto:[log in to unmask]]
Sent: 22 September 2011 12:06
To: Lawrence Serewicz; [log in to unmask]
Subject: RE: [data-protection] email addresses
In this case the DS is a PVP so I am wary of disclosing the name of
someone who may then be targeted with abusive emails - even though their
name is present in a professional capacity.
I think I will redact.
Thanks
Brenda
Brenda Scourfield
Team Leader
I.T.
Pembrokeshire County Council
County Hall
Haverfordwest
SA61 1TP
01437 775380
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Lawrence Serewicz
Sent: 22 September 2011 11:55
To: [log in to unmask]
Subject: Re: [data-protection] email addresses
I agree that it is personal information, but it can still be disclosed
given that it relates to their professional role. Would they be
unjustifiably prejudiced by the disclosure? I could see an argument if
they were a fraud investigation officer, for example, but if they are
not in that type of role, then the prejudice would need to be
demonstrated before withholding. In that regard, I would follow the
arguments of schedule 2 condition 6.
Best,
Lawrence
Principal Information Management Officer
Durham County Council
Room 4/140
County Hall
County Durham
DH1 5UF
0191 372 8371
VPN 77778371
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Jane Holden
Sent: 22 September 2011 11:48
To: [log in to unmask]
Subject: Re: [data-protection] email addresses
In my opinion if it names and identifies an individual then it is
personal information. e.g. [log in to unmask]
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 Brenda Scourfield
Sent: 22 September 2011 11:40
To: [log in to unmask]
Subject: [data-protection] email addresses
That old chestnut I'm afraid........is an email address personal data ?
I am checking letters, emails etc for third party data and have started
to question whether an email adrees of an employee of another large
organisation we are corresponding with regarding the data subject, is
third party data
eg
[log in to unmask]
I have no idea of the position of Fred Bloggs - whether MD or tea boy
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