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What do you think is the position where a member of staff is processing
personal data in connection with providing references for business contacts
who are not our employees but employees of other institutions(including ones
overseas) with which the person was previously associated? The purpose is
not personnel administration for this institution but is personal to the
staff member. Are we a computer bureau for the staff member in question
under the current Act  &  concerned therefore only with the security of the
data(we are registered both as user & bureau). 
If this is so, presumably we would be a processor under the new Act for the
staff member, who as controller would have to notify? This seems bizarre!
Gail Waters
DP Coordinator
Open University



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