Further to all the other comments pointing out the drawbacks of the idea
that photographs should be routinely attached to e-mails, I agree that it
would be difficult to satisfy a Schedule 2 Condition (let alone a Schedule 3
Condition) in the absence of consent. The use of photographs does not
appear to be *necessary* to achieve the safeguarding objective, even if the
other objections had no validity or could be over-ridden (and consent is the
only Condition where necessity is not required). And then you have
old-fashioned people like me who set their e-mail client to display e-mails
as text only, so I would never get to see the photo in the first place,
thus.defeating the purpose again.
Also, if the photographs are attached indiscriminately to e-mails, a
significant proportion will go to people who will never meet the sender face
to face and would not be at risk if they did, which starts to look like a
breach of Principle 3 - excessive for the purpose (and of course Principle 2
if the photos were taken for a different purpose). Sending the e-mails
abroad could bring Principle 8 into play. Others have already mentioned
Principle 4 if the photo goes out of date.
So we have potential breaches of Principles 1, 2, 3, 4 and 8 at least. Any
takers for 5, 6 and 7?
Paul Ticher
0116 273 8191
www.paulticher.com
22 Stoughton Drive North, Leicester LE5 5UB
For continuous priority support on Data Protection, sign up to my support
service:
www.paulticher.com/data-protection-services
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