I'd say 'might not apply' is probably more accurate, as it would - again, sticking to the definitions involved - depend on the extend to which info stored electronically is susceptible to 'operations of an automatic nature' (paraphrase).
NoK details typed into a NoK field in a student's Uni records would seem to be likely searchable by automatic means and thus become fair game to the full gamut of rules & regs. However, could we say the same about a scanned notification (pdf, JPEG, bitmap etc) that was stored in a form 'dumb' enough not to be recognised by search functionality?
Bearing in mind the GDPR drive towards anonymisation or pseudonymisation where possible, there could conceivably be an imperative to look towards this sort of management of 'there - but - not - obvious' information.
Deputy Data Protection Officer
Data Protection Office
Strategy, Performance and Transformation Directorate
Sunderland City Council
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