Dear All
Can anyone offer me any guidance on the following scenario.
My University wants to send alumni data to an external company,
initially so they can provide a quote for data cleaning. The data would
be encrypted and uploaded to the external company's FTP site and the
password would be provided by separate email or by phone. The data
includes names, addresses, student IDs, names and addresses of work for
some, email addresses, telephone numbers and graduation details for
former students. There are approximately 75,000 - 80,000 records that
would be transmitted and the company have signed a non-disclosure form.
The company does process data off-shore in North America but is a member
of the Safe Harbour scheme for ensuring adequate data protection to EU
standards and I see from section B8 of the ICO's new Guide to Data
Protection that the Commission considers that personal data sent to the
US under the scheme is adequately protected.
The reason for the data cleanse is that most of the data was collected
when students first enrolled and much of it is therefore now out of
date. The company uses Raiser's Edge software to automatically update
the personal data from the information it holds, for example from the
Royal Mail re-direction service. I am told that this company and its
software is used by other universities.
I have been asked to consider the transmission from a data protection
viewpoint and so far my concerns are around the fact that this data
cleanse was not anticipated when the University originally collected the
personal data and therefore was not notified to students in a privacy
notice. Should I be concerned about this? Are there other issues I
should be concerned about?
Many thanks
Ann-Marie Noble
Secretariat and Legal Services
University of Lincoln
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