In general these matters depend on what is "reasonable". The "belief" held
by the marketing staff is not from any documented "reasonableness" though it
is not unreasonable.
What you need is a set of policies detailing classes of data and retention
periods for all data that falls within the scope of legislation that
requires or allows retention. IN addition the other side of the pancake is
required: Deletion policies and destruction policies. The two sound
similar, but are not.
Where there is no formal legislative retention period (such as accounting
data) it is up to you to set and to be prepared to back the setting of your
own retention periods. It is fair to invent your own standards for
reasonable retention periods provided you have a rationale for doing so.
With photographs the "personal nature" seems to depend upon the crowd size.
My picture solo is personal data. My pic in a group of two or three is
personal data for each of us. At what point does it turn into a crowd and
become "depersonalised"?
Tim Trent - Consultant
Direct: +44(0)1344 392644 Mobile:+44(0)7710 126618
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Marketing Improvement Limited, Abbey House, Grenville Place, Bracknell,
United Kingdom, RG12 1BP
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-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of datap
Sent: 21 July 2005 11:45
To: [log in to unmask]
Subject: [data-protection] Photographs and retention
Hello all,
I have just spent a large portion of the morning searching the archives and
I am fairly sure that this has not been covered, but apologies if I am
mistaken!
I was wondering if anyone knew of any legislation governing how long we can
keep photographs for marketing purpose? I.e. we take photos of customers at
a public event, get a consent form for use of that photograph in publicity
material / internet etc, but how long can we keep that photo and reuse it
for (consent aside)? Our marketing staff believe it is two years but cannot
say where this figure comes from.
I thank you all in advance.
Best regards,
Tanya Holden
Information Governance Manager
Metropolitan Housing Partnership
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