Postcodes have been held to be personal data (see paras 51-57 of Dundas http://www.informationtribunal.gov.uk/DBFiles/Decision/i128/Dundas.pdf)
Clearly you can't extend Dundas into a general proposition that postcodes will *always* be personal data, but it's worth bearing in mind. And, of course, just because postcodes might be pd does not mean they cannot be processed fairly/lawfully etc.
Getting employees' consent is one option to avoid any potential contravention.
Jonathan Baines
Complaints and Information Rights Officer
Legal and Democratic Services
Buckinghamshire County Council
01296 383681
Follow us on twitter @buckscclegal
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Mike Gater
Sent: 29 November 2013 14:59
To: [log in to unmask]
Subject: [data-protection] Friday question - Data Sharing
I have not yet seen a Friday question today, so I thought I would post one....
Our organisation is looking to share employee postcodes (~2000) with a local council (no other identifiable data will be disclosed). The object of this exercise it to map out each post code and plot this against major public transport routes, with the aim to provide / point out alternative means of transport for our employees. This is in an attempt to reduce the risks of travelling by car, reducing emissions and overcrowded car parking.
I wondered what issues the list could identify, whether other organisations have done this and what justifiable reasons were used to process this information?
Thanking you in advance.
Regards
Mike
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