But they would come under s.7(1)(b)(iii): the recipients or classes of recipients to whom they are or may be disclosed. So then you'd get into partial redactions e.g. leaving the domain in.
Without consent to disclose there's a presumption in favour of not doing so, of course.
Ben Heathcote
Information Security Officer (Compliance)
Information Security & Governance Team
IT Service
Newcastle University
NE1 7RU
Telephone: 0191 208 6950
Email: [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: 11 April 2018 11:11
To: [log in to unmask]
Subject: Re: [data-protection] Redaction
In practice it probably doesn't matter that much.
They will very often not be personal data of the applicant even if the content of the email contains pd and accordingly outside the scope of the SAR. So you can redact them. Technically it would breach DP principles if you did not as no legal basis for disclosure if they are not the applicants PD. Sometimes they will be PD of the applicant and the other person in which case they should not be redacted as there would be no reason to.
On the other hand they are unlikely to be confidential and the applicant already knows them (assuming they were a recipient/ sender) so any breach by just leaving it all in would usually be trivial.
Its one reason why I prefer not to routinely copy 'all' emails but to actively extract the (usually quite small amounts of ) PD from them.
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
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 https://www.jiscmail.ac.uk/help/subscribers/subscribercommands.html
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)
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
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 https://www.jiscmail.ac.uk/help/subscribers/subscribercommands.html
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)
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
|