Is it just me, or do others think that the Information Commissioner
shouldn't describe the one-off disclosure of data, e.g. under s.29, as data
sharing? I find that it confuses the issue, because the basis for sharing
and the basis for disclosure are usually quite different, and the processes
of authorising the disclosure or the sharing are also usually different: a
protocol for sharing, and authorisation procedure for disclosure.
[Prompted by Chris's reference below, but I've been worrying about this for
some time.]
Paul Ticher
0116 273 8191
www.paulticher.com
22 Stoughton Drive North, Leicester LE5 5UB
----- Original Message -----
From: "chris pounder" <[log in to unmask]>
To: <[log in to unmask]>
Sent: Wednesday, October 19, 2011 1:28 PM
Subject: Re: Disclosure of personal data in relation to possible credit card
fraud
> The test is that you have to be satisfied that failure to disclose would
> prejudice prevention/detection of crime.
>
>
>
> If they are saying that "prejudice is possible", I am not sure whether
> that
> is enough. You might have to get them to "firm up" - so to speak.
>
>
>
> You could say that if they contact the police, you would disclose to the
> police.
>
>
>
> Also, see the ICO's data sharing code of practice. This is relevant if you
> decide to disclose.
>
>
>
> You are not obliged to disclose.
>
>
>
> I think these are the issues.
>
>
>
> C
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