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Whilst the FOI regime may be perceived to take precedence in practical
matters, the DP regime is apparently superior in legal terms and hence
should be considered with greater care if rigidly tight or inappropriate
policies are to be avoided.

In a similar but more serious way the need not to physically terminate
people during any work an organisation undertakes should take precedence
over the bottom line as a means of reducing the potential for triggering
changes in employees/customers reactions which would match that risk whilst
still enabling any necessary business to be conducted.

Each organisation will no doubt make their own decisions reflecting their
own cultural outlook and values though.

Ian W


> -----Original Message-----
> From: This list is for those interested in Data Protection
> issues [mailto:[log in to unmask]] On Behalf Of
> Chell, Robert
> Sent: 10 March 2006 10:41
> To: [log in to unmask]
> Subject: Re: Retention periods
>
>
> FOI is a regime, and takes precedence.  The FOIA incorporates
> EIR (s.39) and DP (s.40).  It's more likely that FOI will
> expand to the private sector than get a divorce, dragging EIR
> along under its skirts.
> See
> www.ico.gov.uk/documentUploads/EIR%20-%20Flowchart%20to%20requ
> est%20informat
> ion.pdf for a simple diagram.
>
> Robert Chell
> Records Manager
> Clerk to the Council
>
> Room 111, County Hall
>
> * [log in to unmask]
>
> * 02 920 873327
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