Hi Teresa,
I think I would maybe approach it in the same way as if you were being asked for the email addresses under FOI - would you disclose? Which backs up Steve's approach of whether or not there is an expectation for the address to be disclosed. This may be based on seniority, but I would also think about whether or not a person's email address is included in any material which is published on a website (for example), including in reports etc. which may be part of meeting papers and so on.
It's a tricky one...
Best wishes,
Michelle
Michelle Peel
Information Manager
Transport for Greater Manchester
2 Piccadilly Place, Manchester M1 3BG
Direct line: 0161 244 1123, Extension 701123
www.tfgm.com<http://www.tfgm.com>
Please do not print this email unless you really need to.
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Cotterill, Steve
Sent: 11 February 2016 16:41
To: [log in to unmask]
Subject: Re: [data-protection] sharing of local authority contacts
Hi,
To put it bluntly what would be the legal basis for sharing/disclosure? Would it be 'fair processing' - do the data subjects expect their details to be disclosed to these organisations?
I believe that the ICO do say an email is personal data when it identifies a name and place of work much like your email address.
Based on what you said I would not disclose.
You could always canvass for consent? :)
Steve
________________________________________________________________________________________________________________________________________
Stephen Cotterill
Procurement & Technical Officer
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Gudge, Teresa
Sent: 11 February 2016 15:19
To: [log in to unmask]<mailto:[log in to unmask]>
Subject: [data-protection] sharing of local authority contacts
Hello All
Can I have some views on a question I've been asked please ? We hold lists of local authority contacts which include email addresses. We are asked by other organisations to share a copy of our lists (these are sizeable lists) - can we ??
My sensible head says yes because all this information is in the public sector - BUT - didn't the ICO decide that work email addresses are personal data ?? (which I don't agree with actually)
Some guidance would be gratefully received
Teresa
Teresa Gudge
Information Security & Data Protection Manager ISEB DP, CISM
Information Records Management
Historic England, Room G/60, The Engine House, Fire Fly Avenue, Swindon, Wiltshire, SN2 2EH
Tel: 07717 800989
Email: [log in to unmask]<mailto:[log in to unmask]>
We are the public body that looks after England's historic environment. We champion historic places, helping people to understand, value and care for them, now and for the future.
Sign up to our enewsletter to keep up to date with our latest news, advice and listings.
HistoricEngland.org.uk Twitter: @HistoricEngland
This e-mail (and any attachments) is confidential and may contain personal views which are not the views of Historic England unless specifically stated. If you have received it in error, please delete it from your system and notify the sender immediately. Do not use, copy or disclose the information in any way nor act in reliance on it. Any information sent to Historic England may become publicly available.
________________________________
All archives of messages are stored permanently and are available to the world wide web community at large at http://www.jiscmail.ac.uk/lists/data-protection.html
Selected commands (the command has been filled in below in the body of the email if you are receiving emails in HTML format):
* Leaving this list: send leave data-protection to [log in to unmask]<mailto:[log in to unmask]&BODY=LEAVE%20data-protection>
* Suspending emails from all JISCMail lists: send SET * NOMAIL to [log in to unmask]<mailto:[log in to unmask]&BODY=SET%20*%20NOMAIL>
* To receive emails from this list in text format: send SET data-protection NOHTML to [log in to unmask]<mailto:[log in to unmask]&BODY=SET%20data-protection%20NOHTML>
* To receive emails from this list in HTML format: send SET data-protection HTML to [log in to unmask]<mailto:[log in to unmask]&BODY=SET%20data-protection%20HTML>
All user commands can be found at http://www.jiscmail.ac.uk/help/commandref.htm and are sent in the body of an otherwise blank email to [log in to unmask]<mailto:[log in to unmask]>
Any queries about sending or receiving messages please send to the list owner [log in to unmask]<mailto:[log in to unmask]>
(Please send all commands to [log in to unmask]<mailto:[log in to unmask]> not the list or the moderators, and all requests for technical help to [log in to unmask]<mailto:[log in to unmask]>, the general office helpline)
________________________________
DISCLAIMER:
This email and any attachments are confidential and intended solely for the use of the individual to whom it is addressed. If you are not the intended recipient be advised that you have received this email in error and that any use, dissemination, forwarding, printing or copying of this email is strictly prohibited.
If you have received this email in error please contact the IT Service Desk at Broxtowe Borough Council on [log in to unmask]<mailto:[log in to unmask]> or telephone 0115 917 3194.
Senders and recipients of email should be aware that, under current legislation, the contents may be monitored and will be retained. The contents of the email may have to be disclosed in response to a request.
This disclaimer confirms that this email message has been swept for the presence of computer viruses.
________________________________
All archives of messages are stored permanently and are available to the world wide web community at large at http://www.jiscmail.ac.uk/lists/data-protection.html
Selected commands (the command has been filled in below in the body of the email if you are receiving emails in HTML format):
* Leaving this list: send leave data-protection to [log in to unmask]<mailto:[log in to unmask]&BODY=LEAVE%20data-protection>
* Suspending emails from all JISCMail lists: send SET * NOMAIL to [log in to unmask]<mailto:[log in to unmask]&BODY=SET%20*%20NOMAIL>
* To receive emails from this list in text format: send SET data-protection NOHTML to [log in to unmask]<mailto:[log in to unmask]&BODY=SET%20data-protection%20NOHTML>
* To receive emails from this list in HTML format: send SET data-protection HTML to [log in to unmask]<mailto:[log in to unmask]&BODY=SET%20data-protection%20HTML>
All user commands can be found at http://www.jiscmail.ac.uk/help/commandref.htm and are sent in the body of an otherwise blank email to [log in to unmask]<mailto:[log in to unmask]>
Any queries about sending or receiving messages please send to the list owner [log in to unmask]<mailto:[log in to unmask]>
(Please send all commands to [log in to unmask]<mailto:[log in to unmask]> not the list or the moderators, and all requests for technical help to [log in to unmask]<mailto:[log in to unmask]>, the general office helpline)
________________________________
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
All archives of messages are stored permanently and are
available to the world wide web community at large at
http://www.jiscmail.ac.uk/lists/data-protection.html
If you wish to leave this list please send the command
leave data-protection to [log in to unmask]
All user commands can be found at http://www.jiscmail.ac.uk/help/commandref.htm
Any queries about sending or receiving messages please send to the list owner
[log in to unmask]
Full help Desk - please email [log in to unmask] describing your needs
To receive these emails in HTML format send the command:
SET data-protection HTML to [log in to unmask]
(all commands go to [log in to unmask] not the list please)
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
