Interesting!
I suppose the DC vs Personal Use position will depend to some degree on how mandatory the portfolios are.
If they're mandated by professional bodies but not backed up in a legislative requirement, you could (backed up by various FOI arguments) make an argument that 'personal' equates to 'home' OR that 'personal' includes 'some work-related' info processing.
However, if they're mandated by law (can't think of any off the top of my head), then DPA S1(4) seems pretty clear that anyone maintaining a mandated portfolio is a DC.
Owen
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