"Processing" is defined in s1 to include "holding".
Regards - Michael Bacon
Grimbaldus Limited
> On 19 Feb 2015, at 13:24, Andrew Goodfellow-Swaap <[log in to unmask]> wrote:
>
> Hi,
>
> Re: 'retaining' - aren't we then broadening 'retaining' into processing in general? Given that the section omits any other forms of processing including holding, changing, etc. doesn't it seem that the section has been deliberately restricted to exclude those (which admittedly seems a bit daft in hindsight)?
>
> There is of course a s.21(1) offence as Phil has pointed out and also a likely breach of several principles.
>
> Andrew Goodfellow-Swaap
>
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