"It is during this period that we wish to receive information from the other HA on all aspects of housing management so that we can set up properties and tenants on our systems, set up rent accounts, take details of all outstanding ASB issues etc so some of this information is likely to be sensitive."
So what happens if the sale falls through at the last minute?
It is difficult to see a basis for "sharing" unless you have full individual consent - which goes beyond notice of course. The Irish DPC is at least clear on this: https://www.dataprotection.ie/docs/Transfer_of_ownership_of_Business/217.htm - yes I know the Acts are different but the message is clear.
"all such data, where it constitutes personal data, must be anonymised prior to disclosure to a prospective buyer as there is no basis in the Data Protection Acts for the release of such information as part of the consideration of a merger or acquisition process."
This is not easy. The seller needs to set up a data room, and appoint a processor who is at all times acting on the seller's behalf to prepare the data for transfer upon completion - obviously with input from the buyer to make sure all is compatible etc.
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