Mitchell,Karen wrote:
>
> Dear all
>
> The HR department here is undergoing huge changes and lots of issues are
> surfacing, one of which is that they now want to utilise mailing houses to
> mail out information to our employees on a regular basis, and after a minor
> tussle have accepted the need to inform employees about this and offered me
> the letter below as a starting point to informing employees about this - I
> would appreciate any comments anyone has on the content of the letter or the
> proposed idea.....
> (Am I being over sensitive worrying about the tone of the last couple of
> sentences?)
>
> With thanks
> Karen Jane Mitchell
> Group Records & Data Protection Manager
> The BOC Group plc
>
> July 1999
>
> Dear Colleague
>
> Many of you may know that the Data Protection legislation has been updated
> and amended to provide more protection for individuals and places more
> responsibility on companies that handle personal information. As a Company
> we want to assure you that we take this obligation for our employees very
> seriously.
>
> >From time to time the Company has very important messages that it wishes to
> convey to all employees covering pensions, the Savings-Related share option
> schemes and any new Company 'badged' initiatives that will be of personal
> interest to our employees in the future. To ensure, with any great
> certainty, the employees will receive the communication we have to date
> mailed to home addresses. One new change that the updated legislation
> places on employers is a requirement now to inform its employees when, for
> new purposes in the future, the Company will be mailing to home addresses
> using an external mailing house.
>
> It has been the practice of BOC to use reputable mailing houses to package
> and post literature that we want to get into the hands of all our UK
> employees. I want to take this opportunity to assure you that these third
> parties are not given your personal details for the purposes of soliciting
> business when we issue any communication to the home address. However,
> should you ever decide to take advantage of any products that BOC has been
> able to make available to you through a third party provider then the
> personal information that you supply will not be the responsibility of the
> Group under the Data Protection Act.
>
> Whilst communicating in this complex area of Data Protection, this seems an
> appropriate time to tell you about some of the systems changes the HR
> department is making in the UK as an outcome of the Renew initiative. In
> the next few months BOC will be transferring existing personal data that we
> hold for pay and benefit purposes that is held on a number of HR systems in
> the UK to one streamlined system. This transfer is being done to enable
> your HR department to meet the needs of its employees and the Company more
> efficiently by providing a centralised service. A requirement of the new
> Data Protection legislation is that we tell employees of how their data is
> being used when there is a change such as this and that we gain express
> consent of each employee.
>
> An acceptance form covering the authority to allow data to be transferred
> from several internal HR systems to one internal centralised system is
> attached. This MUST be completed and returned in the envelope provided by
> the end of August. Please note that to withhold consent causes significant
> difficulty and may affect the Company's ability to provide you with even the
> minimum support you currently get from your Personnel Department.
>
> Additionally, this acceptance form gives you the opportunity to give consent
> to the Company to use a mailing house to package and post any important
> internal communication that we wish to send. Again, please be aware that
> you may miss valuable and important messages should you decide to withhold
> consent. The Company cannot be held responsible for non-communication.
>
> Yours sincerely
I was puzzled as to why you need "consent" from the employees if the
only thing the mailing house will do is your own bidding. I.e., it is
merely a processor. You might wish to confirm that this step is
absolutely necessary.
As for consolidating information in a central database, presuming the
control of the data does not pass from the employer, and its use is not
modified, again, do you really need consent?
Regards,
--
Charles A. Prescott
Vice President, International Business Development
and Government Affairs
Direct Marketing Association
1120 Avenue of the Americas
New York, NY 10036
U.S.A.
Tel. (1) 212-790-1552
Fax. (1) 212-790-1499
e-mail: [log in to unmask]
website: www.the-dma.org
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