My feeling, and one that I have also heard from numerous other people, including some lawyers, is that the Information Commissioner's comments on wealth screening were the least well founded of the activities that they penalised the charities for.
 
The point of Data Protection, surely, is to ensure that people are not adversely affected; wealth screening typically leads to people not being contacted because they are not wealthy, more often than to them being contacted.  Where they are contacted the contact is usually delicate rather than intrusive.
 
I'm not saying that there is no transparency issue here, but I sense more push-back on wealth screening (especially where the processing is less automated) than on the other matters - data sharing and data matching - which clearly were unacceptable, at least in the way they were being done.
 
As for self-reporting, the ICO has said that they now want to draw a line under this particular set of investigations, so the risk that they might take action against you if you have recognised the issue and done something about it may not be that great.  (No guarantees, of course.)
 
Best wishes,
 
Paul
 

Paul Ticher
0116 273 8191
www.paulticher.com
22 Stoughton Drive North, Leicester LE5 5UB
 
 
----- Original Message -----
From: [log in to unmask] href="mailto:[log in to unmask]">Cartwright, Christine
To: [log in to unmask] href="mailto:[log in to unmask]">[log in to unmask]
Sent: Wednesday, April 26, 2017 9:34 AM
Subject: Self-reporting

Hi all

 

We’ve received an FOI from a journalist regarding our use of wealth-screening companies and are currently waiting to hear back from the relevant internal team as to our response. Bearing in mind ICO’s recent action against charities for this practice, should it transpire that we have used these companies on a similar scale, I would be interested to know colleagues’ thoughts on whether self-reporting would be advisable to pre-empt the article.

 

Thanks

Christine

 

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