Can't the data shared with your processor be anonymised (or at worst pseudonymised)? If they are analysing performance, I don't see that identifiers need to be part of that dataset.

 

 

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Ben Plouviez

Head of Information Governance - Agriculture and Rural Economy Directorate

The Scottish Government 

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From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Sparks, Alison
Sent: 13 April 2018 14:04
To: [log in to unmask]
Subject: [data-protection] Performance Stats

 

Hi,

 

Can anyone help please? We process Council tax and Benefits as part of our public task.  We have a contract and ISA with a processor to use the data to produce performance management reports for us so that we can allocate resources appropriately.

 

Post May I cannot see how this can continue without the consent of data subjects as it is outside the original lawful basis for which we collected the data and I don’t think I can include performance stats as part of our public task really.

 

At the very least we would need to tell people on our Privacy Notice that we share their data with this other company for performance management as the processor is not actually doing anything to process the claims, just produce reports for us.

 

I’ve been thinking about it for most of the day and can’t see how we can continue to allow them to process the Council tax and benefit data just to produce reports for us – as I can’t fit this into a lawful basis, apart from consent, which of course they could withdraw at any time if they consent in the first place.  Have I missed something or just overthinking?

 

Any thoughts gratefully received.

 

Alison Sparks

 

 

Information Management Team

 

Internal Audit and Information Governance
East Lindsey District Council,
Room 115, Tedder Hall, Manby Park, Manby
Louth, Lincolnshire, LN11 8UP

Tel: 01507 613409
E: information.mangement@e-lindsey.gov.uk
Website: www.e-lindsey.gov.uk  

 

'Lincolnshire's Coastal District'

 

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