Paul Simpkins wrote:
<<A chief executive of as large un-named local authority approaches his HRl
dept for the home address of all the council staff so he can send them all a
letter to their home address concerning the way forward and the challenge
the council faces in the next few years. Can he do this? Did the staff
consent to their home address being used for this purpose when they gave
their details on joining the Council? Is this direct marketing (promoting a
philosophy or a viewpoint?) Are all the addresses up to date? Even a 5%
error rate means thousands going to the wrong address or being returned
undelivered. Doesn't the Council know where its employees work? Can't they
use work addresses? Don't they have Team meetings or briefing sessions?
Before you all rush to reply I asked the ODPC who see no problem with this
mass mailing. Am I going crazy? >>
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Paul
As the mailing is compatible with the reason for processing personnel data -
i.e. it is work related - it is not seen as junk mailing.
As to data accuracy, I'm not sure the council would want anyone to shout too
loudly about this issue. The addresses should be made accurate before the
labels are produced. Provided the information contained within the letter is
non-personal (e.g. all council workers will need to pull together) then if it
does go to the wrong address all that is revealed is that the person works
for the council. There is not so much of a stigma attached to this as there
was in the past and so staff are unlikely to be harmed by the disclosure.
Perhaps the Chief Exec wants to make sure all staff receive it and read it -
and maybe he thinks if it goes in with a payslip employees will throw it away
thinking it is junk mail from Co-op Bank, Frizzell or Zurich Minicipal !!
If this is the reason, perhaps you should tell the CE that some might go
astray unless a data accuracy exercise is undertaken first.
In terms of employee relations, some employers ask their staff if they would
prefer correspondence sent to their work address rather than home.
Ian B
MD
Keep IT Legal Ltd
PS No, you're not going crazy - using that phrase may upset some
contributors to the mailbase - you're just experiencing a feeling of
frustration.
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