This sounds dangerously close to processing of special category PD (ie race/religion) without lawful purpose. And also the fact that just because a person has a name that suggests they may be from a certain ethnic/religious background doesn't necessarily mean that they are - so as you say this is effectively profiling. Having grown up in Northern Ireland I'm all too well aware of this sort of thing! So I would steer well clear.
Ciaran Ward
Information Rights Officer
Guildford Borough Council
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Jude
Sent: 10 January 2019 10:19
To: [log in to unmask]
Subject: [data-protection] University Prospectus - front covers
Our university Marketing / Student Recruitment team are considering publishing a future prospectus with a variety of covers each featuring a head and shoulders close up of one person e.g The person on each of the five front covers would reflect the diversity of the population. The content of the prospectus would be identical. One idea is that the marketing assistant makes a guess from the person's name and address (i.e. the information the requester provides through the online request form) as to which front cover might relate best to them i.e. gender, race. The team have asked for advice whether this is within data protection legislation. One the one hand I think it is standard marketing strategy to try to make your advertising relate to the target audience but on the other hand alarm bells of 'profiling' are in my head. The profiling would just be a guess, but I'm not sure whether this makes is better (i.e. not profiling) or worse (inaccurate). Any thoughts? Do other organisations do something similar and if so do you need to justify and document it?
Thank you
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