It may be worth highlighting the issues Hilary Clinton ran into when using her personal email account for work purposes?!
Mairead Wood
-----Original Message-----
From: This list is for those interested in Data Protection issues <[log in to unmask]> On Behalf Of Donald Henderson - CHX
Sent: 23 November 2018 11:43
To: [log in to unmask]
Subject: Re: [data-protection] Elected Members Private Email Accounts
Individual councillors need individual privacy notices regardless of where they are processing personal data in their role as controllers. It can't be part of the generic council one, because they are separate controllers.
They also need a policy in order to process special category data and an appropriate contract with anyone who processes personal data for them, e.g. the council or email provider.
Basically we drafted them and then told our councillors to sign or provide an appropriate alternative, or we would withdraw all support for constituency casework!
Seems to be working...
Donald
-----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 November 2018 11:14
To: [log in to unmask]
Subject: [data-protection] Elected Members Private Email Accounts
When/if an elected member acts on behalf of themselves in their ward they assume the role of data controller for the processing of constituent personal data, even though they may utilise council resources (i.e. laptop, ipad etc) when doing so.
Does it make any difference if an elected member carries out this work via a private email account (i.e. gmail.com) as opposed to using their council (@-------.gov.uk) provided one? I am trying to determine whether or not they need a separate privacy notice in addition to the generic council one I have written on their behalf, or whether they can rely on the same one because the purpose/s of the processing remains the same?
Although I know this was FOI related, but I am thinking back to the Michael Gove/Mrs Blurt scenario when it was decreed that it wasn't the platform used, but more the content/purpose that dictated?
Would welcome all views.
Regards
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