We are being asked for advice on the use of public health data to provide a better service to the clients. In short the legally held data would be aggregated based on location, ethnicity and potential deprivation to assist with getting clients a better health option. I have stated that data protection legislation does not apply to data that has been rendered anonymous when it has been carried out in such a way that the data subjects are no longer identifiable but the service would like the full postcode information. In a circumstance such as
outcome of service aggregated to say - needs further support, should be referred to service 'A'
The only part I could see that may amount to personal data would be the postcode, if a French (just picked this at random) man lived in a known street with a known postcode it could be reasonable to identify that man from the data despite no name, date of birth or reference number.
What are your thoughts on this? I am being overly concerned? My advice was to redact the postcode to HA1 1XX etc and this would then not identify the part of the road the person lived in meaning a higher level of re-identification would be needed to remove pseudonymisation (yes I looked up how to spell it!)
Thoughts would be appreciated, my current position is no but sometimes aggregated data can assist in sending services to those who need it most and for many do not know it exists.
Thanks for any support
DPO - Harrow Council
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