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Apologies if there's an obvious answer to this one that I'm missing:

We operate several theatres and concert halls which are sometimes hired out
to third parties. When this happens tickets are sold through *our* box
office and personal data (names & addresses) is recorded on our box office
system. We are registered for our own use of this data.

What concerns me is what happens when the third party asks for a list of
names and addresses of the people who bought tickets. We are not registered
for trading in personal information but are we merely an intermediary in
this case (that is, the third party pays for the hall, takes the ticket
money and is clearly responsible for the concert on the publicity and
programmes)? On the other hand, the personal data is on our computer system
not theirs.

My first instinct was not to pass on the information unless we register for
trading in personal information and inform data subjects when they book
their tickets, what do other people advise?

Regards

Gordon

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Gordon Hunt
Head of Information Services
Royal Scottish Academy of Music & Drama
100 Renfrew Street
Glasgow G2 3DB

Tel: 0141 332 4101 x269
Fax: 0141 332 5924
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