"> In practice might avoid problems if social worker simply went round and
> exercised his / her democratic right to inspect the register - no
> questions asked !
Surely that would be "processing" as the social worker is a council
employee, you're a council, and the register is in structured-paper form?"
Yes, it would be 'processing' but I doubt it would be in any way unlawful. The unedited Electoral Register is a public document, so literally anyone able to get to the place it must be made available can turn up, look up, make suitable notes and be on their merry way with lawfully obtained personal data.
Assuming the Social Worker is required by statute to try to trace the child's immediate biological family would satisfy the processing condition at Sched 2(3) straight away.
Incidentally, if I remember correctly, the ERO is required to supply a copy of the unedited register to the Council that appointed them on request and in data format for (presumably) proper Council purposes that need to know who lives where.
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