Jane,
A couple points to consider are whether this would be unfair or harmful to the people. I would imagine that the people receiving the targeting mailing will benefit directly from it.
I think the organisation will have tried to approach these people in other ways. However, many people do not know they are eligible based on what is advertised. The take up on television adverts and other print media is relatively small even though people can benefit from what is advertised.
A targeting mailing, I would assume this is a small percentage of people, would be a very good way to reach these people.
I would imagine you could write a data processing agreement whereby the addresses identified are only used for that single mail shot. If you put it in your mailing, you do face the possibility that you have to pay the postage.
I would be surprised if anyone who would benefit from the service (which is government service (delivered by a private company)) would be aggravated by finding out they are eligible for the service.
However, much of this will depend on your privacy notice and whether the organisation sees a schedule 2 (6) argument for processing the information in this way.
Best,
Lawrence
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Jane Holden
Sent: 12 July 2012 12:14
To: [log in to unmask]
Subject: [data-protection] Data Sharing - Housing & Council Tax Benefit Recipients
Morning
We are being asked by a company, who run a grant scheme on behalf of the Government, for addresses of Housing and Council Tax benefit recipients so that they can do a targeted mailing to ensure a larger uptake of the grant. There is a data sharing agreement template and data sharing would be done on the basis that it will provide us with information on thermal efficiency of the housing stock.
The current eligibility criteria is quite high so it's not just a case of everyone on benefits would be mailed. It would only be those on specific benefits.
Is the sharing fair? necessary & proportionate? in the legitimate interests of the benefit claimant? Etc etc
I must say my initial reaction is one of reluctance.
Any views/advice would be gratefully received.
Many thanks
Jane Holden
Barrow Borough Council - Enhancing the economic and social future of the Borough.
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