At a DP conference for the health sector some time ago, a compliance officer
from ODPR was asked to provide a definition of a structured file. He
ventured the opinion that if you filed data in any way that meant it was
useable then it would probably be regarded as structured.
Stuart Cashmore
Management Information Projects Manager
McKessonHBOC (UK), No. 1 Nine Elms Lane, LONDON SW8 5RR
Tel. 020-7819 5083 (with Voicemail)
Mob. 07799-790019
Fax. 020-7819 5100
e-mail [log in to unmask]
<mailto:[log in to unmask]>
-----Original Message-----
From: GOULDING, Susan - NC [SMTP:[log in to unmask]]
Sent: 13 June 2001 11:06
To: [log in to unmask]
Subject: Re: Structured files
If it's a public authority it will be governed by FOI as well -
which
applies subject access rights to unstructured files, so no easy
escape route
there, I'd have thought.
Su Goulding
Legal Officer, NSPCC
020-7825-1393
[log in to unmask]
-----Original Message-----
From: Hubert, Paul [STU] [mailto:[log in to unmask]]
Sent: 13 June 2001 10:52
To: [log in to unmask]
Subject: Structured files
Paul Ticher suggested:
... an alternative approach might be to have a paper file recording
complaints and outcomes, which is there to demonstrate that you have
followed your procedures, but one that is not 'structured' so that
you can
readily find specific information about particular individuals
(definitions
in s.1) - i.e. perhaps it's just in date order. In this case the
complaints
log may well not be personal data. If it's not personal data, it's
not
covered by the Act, so is not available to subject access.
This to me looks like an evasion rather than an escape route. Is it
a
legitimate method for a public authority to keep information on
people?
There may be Human Rights Act implications to doing it. And how
unstructured
does a file have to be before it escapes? And if so, will it then
have any
valid use at all? If it's stored in date order, you have a way of
relating
the date to the individual and you can within a few minutes find the
information relating to the case of the individual, isn't it
structured
enough? It seems to me likely that the reason Paula wants to keep it
involves relating it to the individual.
Paul Hubert
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