Thanks for the comments.
We have got a SPOC in place for Mr X and also done all (or most) of what you suggest below - the police have taken it upon themselves to attend some of the community council meetings where he may be in attendance due to concerns over his safety as well as others.
It is a complicated situation and whilst appreciating all the comments (and concerns raised) I do wish to assist but obviously need to certain we legitimise the processing.
I will instigate a careful review of the information held and consider it from there as to whether or not S29 is the way forward.
Many thanks
Derek O'Connor
Rheolwr Llywodraethu Gwybodaeth / Information Governance Manager
Cyngor Bwrdeistef Sirol CONWY County Borough Council
E-Bost / E-Mail: [log in to unmask]
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Phil Bradshaw
Sent: 13 May 2015 15:27
To: [log in to unmask]
Subject: Re: [data-protection] Information sharing
Whatever else you do you need to have a proper review & assessment of the material you hold before handing anything over. Whilst I do not disagree with Michelle in principle you cannot simply abdicate responsibility for reasonable and proprotionate assessment as that is part of the 'necessity' test.
Harassment offence includes a specific mens rea "which he knows or ought to know amounts to harassment of the other" - tepered of course by s1(2). Have you for instance ever thought it necessary to warn Mr X that if he persists he might be reported for an offence ? Have you ever used the word harrassment in communications with him ? Have you ever treated an FOI request as vexatious or given notice under s17(6) FOIA? Has the LGA ever warned him or criticised his conduct. Has he been subject to a formal vexatious complainant procedure (if you have one)?
If you have been playing his game by his rules without comment for years he might have cause for further complaint if you suddenly, without warning, hand it all over to the constabulary.
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