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<[log in to unmask]>, at 
10:10:48 on Sat, 6 Nov 2010, "Bradshaw, Phillip" 
<[log in to unmask]> writes
 >>"What if the correspondence in question was about money owed by the
 >>ex-employee[1] to the organisation, and HR and Accounts were 
 >>discussing what remedies they might have?"
>
>I am not saying I agree with Durant, compared with the Directive, but 
>that seems precisely a Durant situation. The focus is on "what renedies 
>do we have to deal with this issue" not on the data subject whose 
>identity is irrelevant. They could have had the same discussion about 
>"employee X".

They might have that generic discussion when deciding what to put in the 
employment contract, but once an incident has arisen they may need to 
discuss the specific details (amounts of money, length of default), to 
see what form of action to take.

>As a side issue as a dp officer I try to avoid such issues arising by 
>training managers not to identify staff when they report an incident or 
>ask for advice. The rule is "if I need to know I will ask, until then 
>keep it anonymous"

That's a good idea, but may not be practicable. Hypothetical example: 
employee at a small school rents the hall in the evening (there's a 
published tariff) and runs a knitting circle whose members are bad at 
paying their subscriptions. Employee is late paying the rent to the 
school. Difficult to anonymise if everyone knows only one employee ever 
rents the hall.

 >>"And does it make a difference if the debt arose before or after his
 >>employment terminated?

 >Probably not. 

Although one remedy, if the amounts were large enough and/or the debt 
was contrary to policy, would be to initiate disciplinary processes that 
might ultimately lead to dismissal.
-- 
Roland Perry

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