Seth,
Assuming you have detailed your processing and how you plan augmenting the
data then DS who opted in can be processed in the way that you outline.
Big problem may be that no one has opted in - you have assumed consent and
given them opportunity to opt out - which may be reminding them of their
rights or may be that this marketing exercise is outside the scope of the
original consent which you obtained? If the latter then you're right to be
concerned.
Ian
----- Original Message -----
From: "Seth Speirs" <[log in to unmask]>
To: <[log in to unmask]>
Sent: Thursday, January 05, 2017 2:55 PM
Subject: [data-protection] Obtaining telephone numbers
How would anyone feel about the following situation:
We are engaged with a reputable market research company to carry out
targetted research on the expereinces of victims and witnesses. As part of
this process we provide persoanl data about them to the company to
facilitate contact. This is all above board and potential subjects are
contacted by letter first to give them an opportunity to withdraw from
consideration.
The company in question is now asking if it can use the services of a
telephone number matching service to add telephone numbers to some of the
subjects - the primary purpose is to increase the pool of potential subjects
and the survey quality in general.
Obviously we could say that htis is nothing to do with us, but obviously the
data we have provided is the basis for the search and obviously there is a
certain reputational issue here.
Other than this there will be no other changes to the way subjects are
contacted.
My initial inclination is that this ought to be ok, but that we should write
this into our inforation ahring agreement.
Seth
Seth Speirs
Assistant Departmetnal Security Officer
Public Prosecuion Service
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