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I would appreciate the views of the List on the following.
The National Audit Office in Wales are carrying out an audit on sickness absence. Most of what they require is statistical however, they have received NI numbers for 100 staff in each Trust (how is another issue, but not part of this submission). They require each Trust to identify the 100 staff from the NI numbers(their own 100 not the whole batch) and send them an NAO questionnaire to be completed and anonymously returned to the NAO.
I have questioned their processing of NI numbers as not being lawful (and therefore our subsequent processing), as it is not for tax or benefits purposes. Their legal advisers are suggesting (interesting choice of word) that it is ok to process because of "the distinction between disclosure and use within the 1992 Social Security Act and the applicability of the Act in this particular instance"?
They are obviously not sure of their ground as they are now passing it by the Welsh Assembly Governments legal people.
My understanding is that you can only use NI numbers for tax or benefit purposes, are List members aware of exemptions to this?

Nic Drew
DPO
Cardiff & Vale NHS Trust






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