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Sounds like it's acting as if it were a distribution group, albeit poorly administered.

Also interested to see whether the emails are pertinent to the recipients' employment on a work mailbox and therefore as I understand exempt from opt out.

Ian



> On 18 Sep 2018, at 08:33, Palmer-Dunk, Daniel <[log in to unmask]> wrote:
> 
> So its not a discussion group like JISC mail lists (ie, this one), but unsolicited emails/complaints?
> 
> Article 21(1) applies if they are sending the emails to personal accounts (not group mailboxes) based on legitimate interests (Article 6(1)(f)).  The recipients could write to them and object (or you could do it corporately on behalf of them, perhaps) but then it's down to them to decide whether to stop sending them or not.  If they still receive them the recipients could then complain to the ICO and the senders can demonstrate how they have conducted a balancing exercise of their compelling legitimate grounds against the interests, rights and freedoms of the recipients(!).
> 
> If it could be classed as marketing there could be an absolute right to object, but I doubt whether that would make a difference to whether they continue to send them either.
> 
> I think there are potential options open to the recipients, but perhaps this receiving unsolicited complaints is perhaps just a cost of business of being a council employee!
> 
> Dan
> 
> P.S apologies for the earlier blank reply! 
> 
> -----Original Message-----
> From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Lindsay Foody
> Sent: 17 September 2018 16:30
> To: [log in to unmask]
> Subject: Re: [data-protection] Unsubscribing from Contributor to Email Discussion Group
> 
> Many thanks
> 
> It's processing on behalf of the Council; it's emails from what could be termed pressure groups / special interest groups which individuals are copied in to and where we are not the originator of the email.  Sorry for not making that clear originally.
> 
> Regards
> 
> Lindsay
> 
> 
> 
> -----Original Message-----
> From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Phil Bradshaw
> Sent: 17 September 2018 10:12
> To: [log in to unmask]
> Subject: Re: [data-protection] Unsubscribing from Contributor to Email Discussion Group
> 
> Assuming this is within a work environment your use of the email address is on behalf of your employer as controller and would seem to be under point (e) of Article 6(1).
> 
> Unless person can bring themselves within Art 21 (grounds relating to his or her particular situation) I would suggest you can simply continue with reply all and if person objects refer them to the list controller. If they DO bring within Art 21 but want to remain on the list I would certainly see you may have a compelling argument for doing the same - it is their choice to be on the list with all that goes with it. It should not be for you to weed them out.
> 
> ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
>     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 https://www.jiscmail.ac.uk/help/subscribers/subscribercommands.html
> 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)
>    ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
> 
> <http://www.kirklees.gov.uk>
> [http://www.kirklees.gov.uk/beta/assets/global/img/logo_kirkleesCouncil_x2.png]
> 
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> 
> This email and any attachments are confidential. If you have received this email in error – please notify the sender immediately, delete it from your system, and do not use, copy or disclose the information in any way. Kirklees Council monitors all emails sent or received.
> 
> ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
>     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 https://www.jiscmail.ac.uk/help/subscribers/subscribercommands.html
> 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)
>    ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
> 
> ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
>     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 https://www.jiscmail.ac.uk/help/subscribers/subscribercommands.html
> 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)
>    ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^

^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
     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 https://www.jiscmail.ac.uk/help/subscribers/subscribercommands.html
 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)
    ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^