Simon
Re section 28 comment. I agree, poor choice of words on my part.
David Wyatt
----- Original Message -----
From: "Simon Howarth (RGC) Interim Information Governance Manager"
<[log in to unmask]>
To: <[log in to unmask]>
Sent: Wednesday, February 22, 2006 12:04 PM
Subject: Re: [data-protection] DVLA Data share
Very interesting. Being a member of at least two of the quoted organisations
who have been approached for consultation, I feel I may have to write and
have my views expressed.
The document might have been better proof read, but apart from that I think
there is food for thought, and I am certainly in favour of a two tier
approach with organisations requiring to be a member of a regulatory body to
have access to information.
I also think that they spend a lot of time worrying about putting charges up
from £2.50 to £6 or whatever. My view would be to put the charge for "one
off" requests to £10, the same as an SAR, with an appropriate charge for
organisations grante conditional access.
The procedure for policing the system should also be considered carefully;
there should be punitive action taken for abuses by, for example, car
parking/clamping companies.
As for the suggestion that the "Data Protection Registrar" should be checked
- by this I think they mean the Register of Data Controllers - what a good
idea! Although maybe it could be argued that the organisations should be
only data processors, supplied the information by the DVLA for only a single
purpose with controllership residing with the DVLA?
I am not sure of your point with regard to Section 28 of the Road Vehicles
Regulations, as it does not really "restrict what can be shared in terms of
personal data", it just restricts what the Secretary of State can sell under
the terms of the section and regulations.
Simon Howarth.
-----Original Message-----
From: David Wyatt [mailto:[log in to unmask]]
Sent: 21 February 2006 23:22
To: [log in to unmask]
Subject: [data-protection] DVLA Data share
Of Interest to DPA / HR practitioners or impacted data subjects?.
Vehicle Keeper data sharing consultation
DoT Consultation ends 31 March 2006
Information Commissioner on list of consultees presumably to represent the
interests of those data subjects impacted.
See details at :
http://www.dft.gov.uk/stellent/groups/dft_roads/documents/page/dft_roads_611
202.hcsp
Consultation document
http://www.dft.gov.uk/stellent/groups/dft_roads/documents/pdf/dft_roads_pdf_
611202.pdf
Data Protection and Human Rights are a key feature in the review
See Section 27 and 28 of the SI 2002/2742 re current statutory basis for
vehicle keeper data sharing in UK - last para section 28 has strong DPA
compliance link. The DoT consultation paper omits referencing section 28
placing the emphasis on section 27 and the 'reasonable cause' definition as
current basis for sharing./ trading in data. Section 28 restrict what can be
shared in terms of personal data.
http://www.opsi.gov.uk/si/si2002/20022742.htm
David Wyatt
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
All archives of messages are stored permanently and are
available to the world wide web community at large at
http://www.jiscmail.ac.uk/lists/data-protection.html
If you wish to leave this list please send the command
leave data-protection to [log in to unmask]
All user commands can be found at : -
http://www.jiscmail.ac.uk/help/commandref.htm
Any queries about sending or receiving message please send to the list owner
[log in to unmask]
(all commands go to [log in to unmask] not the list please)
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
All archives of messages are stored permanently and are
available to the world wide web community at large at
http://www.jiscmail.ac.uk/lists/data-protection.html
If you wish to leave this list please send the command
leave data-protection to [log in to unmask]
All user commands can be found at : -
http://www.jiscmail.ac.uk/help/commandref.htm
Any queries about sending or receiving message please send to the list owner
[log in to unmask]
(all commands go to [log in to unmask] not the list please)
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
All archives of messages are stored permanently and are
available to the world wide web community at large at
http://www.jiscmail.ac.uk/lists/data-protection.html
If you wish to leave this list please send the command
leave data-protection to [log in to unmask]
All user commands can be found at : -
http://www.jiscmail.ac.uk/help/commandref.htm
Any queries about sending or receiving message please send to the list owner
[log in to unmask]
(all commands go to [log in to unmask] not the list please)
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
