Having personally reflected on this in the past the issue seems like a
reflection of the past. To elaborate from a digital environment
perspective, and raise some questions.
A data controller is processing
data excessively (disproportionately for the purpose).
A data subject
submits a subject access request.
The data controller, claiming
disproportionality, responds in a proportionate way.
Where lays the
truth in that situation?
What motivations exist (other than the
immediate financial ones – a minimum cost these days) for the data
controller to improve their processes if the excessive data processing
really is an accident in design rather than a design by accident?
Do
the supported motivational forces have to be positively countered by
data controllers in directing their organisations or are they naturally
supportive of developments? Where is the greater threat?
A heads up or
a heads down?
Ian W
-----Original Message-----
From: This list is
for those interested in Data Protection issues [mailto:data-
[log in to unmask]] On Behalf Of Phil Bradshaw
Sent: 25 April
2012 15:52
To: [log in to unmask]
Subject: Re: [data-
protection] Subject access
Wonder if ICO will now acknowledge the
Ezsias principle on proportionality of SAR searches ?
----- Original
Message -----
From: [log in to unmask]
Sent: 04/25/12 03:14
PM
To: [log in to unmask]
Subject: [data-protection]
Subject access
Interesting new case on subject access under DPA:
http://www.panopticonblog.com/2012/04/25/subject-access-requests-–-mixed-motives-and-proportionate-searches/
The Ezsias case mentioned - I have done an article on this :
http://www.actnow.org.uk/content/46
Regards
Ibrahim Hasan
Www.actnow.org.uk
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