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Have a look at an FOI Decision Notice (Holy Trinity Church FS50236990 3
August 2009).

It related to a request for residential postcodes of children & staff of a
school. ICO decided that the full postcode is PD, but not Outbound code
(e.g. LS21).

Also, have a look at the House of Lords case CSA v SIC - the key question is
whether the individual can be identified by other information in the
possession of the data controller.

One of the most interesting things is that there is more on "what is
personal data?" coming out of the FOIA regime. That is why we cover it in
our UPDATE sessions with our colleagues at Pinsent Masons (www.amberhawk.com
for details - a non too subtle Xmas marketing message).

Merry "whats its" for those still on-line.

Chris


-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Matt Morrison
Sent: 22 December 2009 10:59
To: [log in to unmask]
Subject: [data-protection] Postcodes request

Hi all

Very boring pre-Christmas query I'm afraid - we've received a third party 
request asking for postcode information of our students in order to do a 
mapping exercise of where students live.

Two things:

1) In terms of personal data, the postcodes won't identify any individual 
addresses although I am aware of an ICO decision notice that said full 
postcodes did constitute personal data, even where they cover more than one 
address.

2) We do not inform our students of this use of their data so I am 
struggling to get past principle 2.

Has anyone dealt with a similar request?

Thanks

Matt Morrison

Information Rights Officer
University of Bristol
[log in to unmask]
0117 3317751 (ex.17751)

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