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Dear Peter
Absolutely - it was review of the Student Privacy Notice that brought this up.
Kind regards
Anne
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Peter Dinsdale
Sent: 20 April 2018 08:58
To: [log in to unmask]
Subject: Re: [data-protection] Council Tax
Hi Anne,
I'd agree with your analysis - that's how I would have justified it if I were still working in HE. The other key, of course, is being clear and transparent about it - a clear statement in your student privacy notice giving details of how to opt out should achieve this.
Regards,
Peter
Peter Dinsdale
Data Protection Consultant
Perfect Image /
T: 0191 238 0111
www.perfect-image.co.uk
Follow us on Twitter http://twitter.com/perfectimage
-----Original Message-----
From: This list is for those interested in Data Protection issues <[log in to unmask]> On Behalf Of Anne Jolly
Sent: 20 April 2018 08:40
To: [log in to unmask]
Subject: Re: [data-protection] Council Tax
Hi all
Well, having done some hard thinking on this, I've decided that our legal basis is legitimate interests (purpose - prevention of fraud, quicker application of benefit for students, more efficient for us; necessity (which doesn't have to be essential) - efficient, not particularly intrusive as very low level of shared data; balance of interest - very little intrusion, some students will get benefit they weren't aware of/ hadn't claimed, saves them contacting us for proof, verification for fraud prevention is more reliable than letters as communication is direct).
ICO have some new guidance on LIA's that's very useful. The council will be relying on public interest for this transfer, but it's clearly not part of our public task, but legit interests can include for the wider public interest...
No legal obligation that I can track down.
No contract.
Consent would be cumbersome (they have the right to object, highlighted, if they don't want sharing under LI) No vital interests.
Looking forward to your contrary views!
Kind regards
Anne
-----Original Message-----
From: Jeanette Harrison [mailto:[log in to unmask]]
Sent: 19 April 2018 16:00
To: Anne Jolly <[log in to unmask]>; [log in to unmask]
Subject: RE: Council Tax
I didn't get very much back Anne. I think I was going to have to get their consent to share information with the Councils - there is no legal requirement for us to share that information as far as I know. I might try speaking to my local council. I'm going to have to update the data sharing agreements too.
Jeanette Harrison
Head of Compliance| Academic Services
Southampton Solent University | East Park Terrace | Southampton SO14 0YN
T: 023 8201 3085 | E: [log in to unmask] | W: solent.ac.uk
Disclaimer
-----Original Message-----
From: Anne Jolly [mailto:[log in to unmask]]
Sent: 19 April 2018 13:18
To: [log in to unmask]; Jeanette Harrison <[log in to unmask]>
Subject: Re: Council Tax
Dear Jeanette
Did you get any response to this? Can anyone else add to this? Do you all seek consent or not provide information to local authority?
Kind regards
Anne
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