Sir, I, Sancho Panza, Salute you, the worthy holder of the name and title, Don Quixote!

On 3 Mar 2010, at 13:54, Ian Welton wrote:

Tim Trent on 03 March 2010 at 12:4 said:-

"May I commend, data mismatching considerations apart,  http://www.ico.
gov.uk/complaints.aspx "

What! and miss all of the experiential privacy issues which are raised
by a lack of compliance with the data protection legal regime!

Ian W

-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]]On Behalf Of Tim Trent
Sent: 03 March 2010 12:43
To: [log in to unmask]
Subject: [Norton AntiSpam] Re: [data-protection] Transmission of Data
to External Company for Cleaning


May I commend, data mismatching considerations apart, http://www.ico.
gov.uk/complaints.aspx and http://complaints.tpsonline.org.uk/Consumer/
to you.


I'm assuming you are TPS registered.


On 3 Mar 2010, at 12:30, Ian Welton wrote:


Moved into house.  Arranged new telephone service which included a
new
number.

An energy company(EON) subsequently and regularly telephones the new
number asking for the previous resident of the property by name, when
asked they do confirm the address and telephone number called; That
previous owner never had any relationship with the telephone number
at
this property.  Despite, every time so far advising them of this and
asking them to remove the data from their call lists, the calls
persist
(which is a different matter to the data matching, but relevant to
mismatched data problems). They hang up the phone promptly when asked
for details about the data matching or contact details for their call
centre.  The result is a most exasperating situation, as, contrary to
what they state they clearly do not do what they say they will do,
even
after providing an operator number/name and promising to act or
stating
they were doing it as they speak. This is a situation which has
continued over a number of years so I think is a prime example for
this
type of dysfunctional consequence.

At one stage I began to wonder if they were providing the wrong
identification, but having quietly increased my information about
this
over a number of years am content they give the correct company
details
for the ‘sales’ call.


Ian W


-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Ann-Marie Noble
Sent: 02 March 2010 16:59
To: [log in to unmask]
Subject: [data-protection] Transmission of Data to External Company
for Cleaning


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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