Hello all,
I would be grateful for advice in relation to the following scenario:
An individual applied to do a PGCE course with us and stated that he had
criminal convictions on his application form. As standard, the course he
applied for requires a CRB check. When the individual was notified that
this check was to take place (he would have already been informed that
this was necessary) he responded by writing a letter asking us to withdraw
his application and remove any reference to him from our records.
Im taking his letter as a Section 10 notice. We have already returned his
application form but we still hold his details and the course he applied
for on our system. From Section 10 it appears that the data subject must
demonstrate that he is, or is likely to, suffer substantial damage or
distress from the processing and that this distress is unwarranted. Whilst
I believe it would be relatively easy to remove all traces of this
individual from our system are we compelled to do so if the individual has
not explained what this distress is likely to be? We may need the details
for reporting drop out rates, withdrawn applications etc (still checking
this). I assume that as consent has been withdrawn we would have to find
another Sch 2 reason to keep the details?
Would be grateful to hear from anyone else who has had a similar
experience? I have to say I'm more than a little suspicious which may well
be clouding my judgement!
Happy friday!
best regards
Matt Cooper
Records and Information Manager
University of Wales, Newport
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