Piers,
Leavers....
I don't think you are missing anything and I think that Sch 2(6) would be
met if the information was used to simply inform departments that X has left
the building and to arrange to have X removed from distribution lists etc.
This is especially important in the NHS, for example, where X might use
nhs.net as their email. Nhs.net follows you around. So if no one is told
they have left, then X may still receive information to which they are not
entitled. You may have web-based systems that they need to be removed from
too.
However, there is no substitute for a proper leavers process and policy!
So processing for 2(6) seems fair to me.
Simon Howarth MBCS CITP
www.informationedge.co.uk
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Piers Margetts
Sent: 04 July 2012 16:05
To: [log in to unmask]
Subject: Re: [data-protection] Two quick questions ACPO guidance and
Leavers/New arrivals.
Lawrence,
Form can be found at the end of their Data Protection Manual - I could not
find it on the ACPO website but it is on the Home Office website at:
http://www.homeoffice.gov.uk/about-us/freedom-of-information/released-inform
ation1/foi-archive-crime/13869_HO_guide_info_crime_victim?view=Binary
All the best,
Piers
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Lawrence Serewicz
Sent: 04 July 2012 15:35
To: [log in to unmask]
Subject: [data-protection] Two quick questions ACPO guidance and Leavers/New
arrivals.
Dear All,
I am trying to track down the document that contains the ACPO's suggested
s.29(3) form. I have an old link that no longer works, but I cannot find
anything on the ACPO site. Any help would be appreciated. The old document
that had the s.29(3) form had guidance to police on using the form and what
they needed to submit the form.
The second question is about recording people who are new arrivals and
latest leavers. In a large organisation, there are people who join and it
is a good idea to welcome them by identifying them. At the same time, the
organisation also recognise those who are leaving the organisation (without
explaining why). Both sets of information are useful for internal practice,
avoiding sending an email to someone who is no longer with the authority,
and knowing if someone should not have access to systems if they are no
longer an employee.
Does anyone see any DPA issues with circulating a list of leavers internally
to an organisation? I can see a schedule 2 Condition 6 reason). However, in
discussions someone has said that the person has left so should the
organisation still be processing the information in that way. My view is
still that schedule 2 Condition 6 is met.
Is it obviously ok or am I missing something?
Any advice would be appreciated on handling leavers lists.
Thanks
Lawrence
Principal Information Management Officer Durham County Council Room 4/140
County Hall County Durham
DH1 5UF
03000 268038
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