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On Wed, Jul 21, 2004 at 10:50:18AM +0100, Ian Welton wrote:
> > However, the Commissioner has stated that they don't have to provide
> > this information in response to an SAR.
> From the brief description you give that seems hardly legitimate.  I wonder
> what the organisational/inter-organisational structure is.
> One must assume they clearly outline these actions within their privacy and
> terms of use policies, updating them whenever they make any consequential
> change to the logical method of processing the data.  I suppose they hook
> that up with the existing software change management process.

Nope. They don't outline these at all. I only know that it happens
because I wrote the systems!

> Do they conduct any collection of information from other cookies which may
> be on the users machine?

No - that's pretty much technical infeasible - most cookies can only be
accessed by the site which set them.

> It will be interesting to see what arguments have been used on both sides to
> result in the stated outcome.

My argument is "they have the information, and aren't providing it".

BlackStar's is "we don't have the information, and if even we do, then
you're not getting it, and even if we've already given you some of it
in an unintelligible form, then we're certainly not going to explain it".

The OIC's argument basically boils down to "if you can't show how you're
actually harmed by them not giving or explaining the information, then
we don't have time to pursue the matter".

Tony

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