Stewart
My observations.
This use appears to be a new purpose different to the security purpose the
data was originally captured for.
Guidance has always been that any new purpose of which the data subject is
unaware that arises after the data is already in your possession, needs
subsequent consent of the data subject.
This links to fufilling your obligations to your data subjects of fair
obtaining and processing and ensuring appropriate security exists
agianst disclosure. A data controllers obligations are to protecting the
data as required under the Act not trying to make assumptions on what the
individual data subject may want you to do. Straying into that area creates
risks for compliance.
Hope this assists
David Wyatt.
----- Original Message -----
From: "Turner8" <[log in to unmask]>
To: <[log in to unmask]>
Sent: Tuesday, September 14, 2004 2:11 PM
Subject: [data-protection] Use of photograph on an application form
>A colleague of mine has asked if he can use the security photograph from
>the
> HR database of one of his staff to send on the booking form for the labour
> party conference.
>
> The member of staff is currently off sick so cannot easily be contacted
> for
> permission.
>
> Any suggestions? What should I do?
>
> Stewart
>
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