Thanks everyone so far.
The main question relates to the return, ie. consent is assumed for the
delivery but does that extend to a collection at a later date.
The specific circumstance is that the retailer sent the item but before it
arrived the customer called to change their mind so the retailer sent the
other one as well. Hence the customer now has two and isn't in any hurry to
return the first one.
Ian
----- Original Message -----
From: "Jane Holden" <[log in to unmask]>
To: <[log in to unmask]>
Sent: Wednesday, September 17, 2014 10:21 AM
Subject: Re: [data-protection] Passing customer details on to a courier
I agree. As a consumer using an online retail site I expect, by the nature
of the transaction that the retail site will have to disclose certain
information about me, including to a courier service, in order for the goods
to be delivered/returned
As a regular online purchaser :) I receive notification/documentation
informing me that an appointed courier will deliver/collect my items.
It's a natural expectation of the customer.
Jane
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Baines, Jonathan
Sent: 17 September 2014 10:08
To: [log in to unmask]
Subject: Re: [data-protection] Passing customer details on to a courier
Isn't this a situation where the processing is necessary for the performance
of a contract to which the data subject is a party?
Or am I missing something?
Jon Baines,
Chairman
www.nadpo.org.uk
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Paul Ticher
Sent: 17 September 2014 09:26
To: [log in to unmask]
Subject: Re: [data-protection] Passing customer details on to a courier
This is harder (to me, at least) than it looks, because it's not something I
would bother thinking about normally. Imagine you told the customer that
you are about to send them a consignment but you can't tell the courier
their name and address 'because of data protection'.
That suggests to me that in giving the name and address you almost certainly
have the customer's consent (thus meeting Schedule 2) provided you have
informed them that the delivery will be made by courier (Principle 1
Transparency and Principle 2). Your data is presumably relevant and
accurate (Principles 3 and 4), and if the goods are secure, the data is
secure (Principle 7). I can't see an issue with Principles 5, 6 or 8.
An address on its own, however, is not personal data. So if you are worried
you could always omit any personal details (but might end up delivering to
the wrong person).
I refuse to discuss whether the courier is a Data Controller or Data
Processor, but I suspect the former.
Paul Ticher
0116 273 8191
www.paulticher.com
22 Stoughton Drive North, Leicester LE5 5UB
For continuous priority support on Data Protection, sign up to my support
service:
www.paulticher.com/data-protection-services
----- Original Message -----
From: "Ian Griffiths" <[log in to unmask]>
To: <[log in to unmask]>
Sent: Tuesday, September 16, 2014 12:34 PM
Subject: Passing customer details on to a courier
> Quick one, can someone just confirm for me as a retailer which sections of
> the act I'm relying upon in order to be able to pass a customer's address
> on to a courier?
>
> Furthermore would that extend to allowing the courier to pick up a return?
>
> Assuming no additional correspondence with the customer after the initial
> sale except to tell them the stuff would be being collected. ie. no
> additional permission saught.
>
> Thanks
>
> Ian
>
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