I had to deal with something similar when they wanted to put photo on the 'email account' i.e. when someone sent an email their image would also be sent.
Aside from the lack of 'necessary justification' for an image to appear on an email I also raised issues of 'security of image (can it be copied and pasted and misused - what is in place to sop unauthorised processing?) and will the image go outside of the organisation.
When I was told the justification for this was 'it will be nice to know what the person sending you the email looks like', I smiled politely and made sure the data subject agreed explicitly to their image being attached to the email to allow it to happen.
Possibly hard to argue but can you also identify some sensitive data from an image (religion / medical condition / ethnic origin)?
I think you will struggle for necessity, so explicit consent needed.
Regards
Steve
________________________________________________________________________________________________________________________________________
Stephen Cotterill
Procurement & Technical Officer
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Derek O'Connor
Sent: 23 October 2015 09:39
To: [log in to unmask]
Subject: [data-protection] Staff Photos on the Intranet
Staff have photos taken and these are incorporated into their chipped ID cards, I am unclear at this point exactly what they have been advised with regards to fair processing and am checking this out, but assuming that that had been done correctly could I elicit any views/concerns if the organisation then wished to use that same photograph (or a new one) to put faces to names on the a staff 'Who's Who' poster for internal use only?
I thinking schedule 2(6) would cover it, obviously some won't like it and will object (s10) but would have to provide information supporting that it would cause substantial damage or distress, which is unwarranted.
Welcome your views.
Regards
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
All archives of messages are stored permanently and are
available to the world wide web community at large at
http://www.jiscmail.ac.uk/lists/data-protection.html
If you wish to leave this list please send the command
leave data-protection to [log in to unmask] All user commands can be found at http://www.jiscmail.ac.uk/help/commandref.htm
Any queries about sending or receiving messages please send to the list owner
[log in to unmask]
Full help Desk - please email [log in to unmask] describing your needs
To receive these emails in HTML format send the command:
SET data-protection HTML to [log in to unmask]
(all commands go to [log in to unmask] not the list please)
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
DISCLAIMER:
This email and any attachments are confidential and intended solely for the use of the individual to whom it is addressed. If you are not the intended recipient be advised that you have received this email in error and that any use, dissemination, forwarding, printing or copying of this email is strictly prohibited.
If you have received this email in error please contact the IT Service Desk at Broxtowe Borough Council on [log in to unmask] or telephone 0115 917 3194.
Senders and recipients of email should be aware that, under current legislation, the contents may be monitored and will be retained. The contents of the email may have to be disclosed in response to a request.
This disclaimer confirms that this email message has been swept for the presence of computer viruses.
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
All archives of messages are stored permanently and are
available to the world wide web community at large at
http://www.jiscmail.ac.uk/lists/data-protection.html
If you wish to leave this list please send the command
leave data-protection to [log in to unmask]
All user commands can be found at http://www.jiscmail.ac.uk/help/commandref.htm
Any queries about sending or receiving messages please send to the list owner
[log in to unmask]
Full help Desk - please email [log in to unmask] describing your needs
To receive these emails in HTML format send the command:
SET data-protection HTML to [log in to unmask]
(all commands go to [log in to unmask] not the list please)
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
|