People,
You may or may not recall that some weeks ago I raised the question as to whether Investigators when acting for clients were controllers or processors. The ICO is of the opinion that they are controllers. Many of you were kind enough to send me your views and various references. I am still researching my paper on this topic.
I have received the ICO's current view as a result of an FOI request and if any of you are interested in its contents e mail me separately and I will forward it to you. It is an interesting read although I don't think that they address the main issue of "determining manner and purpose."
If the ICO have this view with regard to investigators logic dictates that they are likely to have a similar view with any other body that collects personal data for a client. Accountants, Solicitors etc.
Many years ago when this matter first arose the Law Society (if I remember correctly) held the view that Solicitors where processors when acting for their clients. The ICO was of the opinion that they were controllesr.
If there is anyone in this group who belongs to the Law Society or who could point me in the right direction to ask them if this is still their view and why would you be kind enough to e mail me privately?
Many thanks
Chris Brogan MA LLM FSyI
Managing Director
Security International Ltd
11 Loveday Road, London, W13 9JT
Tel: +44 20 8579 8703 Mobile: 07836 226 229
Registered in England & Wales No. 1322074
Registered Office: 11 Loveday Road, London W13 9JT
www.securitysi.com
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