Thanks Robert and Dan, that makes perfect sense.

-----Original Message-----
From: Scott, Robert J <[log in to unmask]> 
Sent: 20 January 2020 11:07
To: Stacey Kennedy <[log in to unmask]>; [log in to unmask]
Subject: RE: [data-protection] If consent is difficult to withdraw...?

Yes, I would state you can use consent however you will need to ensure people realise that whilst they can withdraw consent this would not be prevent anything already in physical circulation so perhaps cite a cut off point for withdrawing from the activity whereby following this they would be withdrawn from the next printing run etc. The ICO explain this somewhere in more depth though the following is relevant;

'If someone withdraws their consent, this does not affect the lawfulness of the processing up to that point. However, it does mean you can no longer rely on consent as your lawful basis for processing. You will need to stop any processing that was based on consent' 

Found here; https://eur03.safelinks.protection.outlook.com/?url=https%3A%2F%2Fico.org.uk%2Ffor-organisations%2Fguide-to-data-protection%2Fguide-to-the-general-data-protection-regulation-gdpr%2Fconsent%2Fhow-should-we-obtain-record-and-manage-consent%2F%23how6&amp;data=02%7C01%7CStacey.Kennedy%40jncc.gov.uk%7C851d06808f8c46d11c8408d79d98d52c%7C444ee4e8b2fd491d8c318b0508370a6b%7C0%7C0%7C637151152048721922&amp;sdata=HlPIb5KPkc2dXcMGtYNz0f9I6omIrQDpgsJf6%2BjX9P8%3D&amp;reserved=0 

Kind regards


Robert J Scott
Data Protection Officer
Central Secretariat
Imperial College London
South Kensington Campus
Level 4 Faculty Building
London, SW7 2AZ

Tel: +44(0) 20 7594 3502

Email: [log in to unmask] 
https://eur03.safelinks.protection.outlook.com/?url=www.imperial.ac.uk%2Fdata-aware&amp;data=02%7C01%7CStacey.Kennedy%40jncc.gov.uk%7C851d06808f8c46d11c8408d79d98d52c%7C444ee4e8b2fd491d8c318b0508370a6b%7C0%7C0%7C637151152048721922&amp;sdata=0Wdd28WiZIV49v03UlUdSQ8SRPiTXy7wJzV1Hh4Vah0%3D&amp;reserved=0
 



-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Stacey Kennedy
Sent: 20 January 2020 10:55
To: [log in to unmask]
Subject: [data-protection] If consent is difficult to withdraw...?


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We are collecting data that may be used to be published in a book. People can submit the data via Office 365 Forms, this processing is being done under public task. The creator has then asked for consent to publish their name with the data, their name is not required if they don't want it published, but can it be consent if it would be impossible to withdraw it from a published book?

Thanks

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