I think senior management such as CEO and Directors are probably fair
game on a public website as they are more likely to be known but not
everyone else!
E
>>> FINCHAM LUCY <[log in to unmask]> 02/05/2008 11:41 >>>
I would probably argue that names and job titles are not personal
data. Photos are.
Regards
Lucy Fincham
University of Greenwich, a charity and company limited by
guarantee, registered in England (reg no. 986729). Registered
Office: Old Royal Naval College, Park Row, Greenwich SE10 9LS.
Date sent: Fri, 2 May 2008 11:36:55 +0100
Send reply to: Julie Gibbs <[log in to unmask]>
From: Julie Gibbs <[log in to unmask]>
To: [log in to unmask]
Subject: Re: [data-protection] Publishing Staff
Information Online
> I can't see how the publication of staff names, job titles and
> photographs worldwide is "necessary" for the purposes of the
legitimate
> interests of the data controller so the schedule 2 condition is not
> applicable in my opinion. The first principle is also being breached
as
> staff have not been informed. Aside from that there is also the
eighth
> principle to consider.
>
>
>
> Julie Gibbs
>
> Information Officer
>
> Crewe & Nantwich Borough Council
>
> Tel: 01270 537733
>
> Fax: 01270 537025
>
> [log in to unmask]
>
>
>
> From: This list is for those interested in Data Protection issues
> [mailto:[log in to unmask]] On Behalf Of Joe Sutton
> Sent: 02 May 2008 11:12
> To: [log in to unmask]
> Subject: [data-protection] Publishing Staff Information Online
>
>
>
>
>
>
>
>
> I would like some opinions on how people see this panning out, if
you
> would not mind!
>
> A decision was made to publish a document containing staff names,
job
> titles, and photographs on the internet. No permission from staff
was
> sought, the Schedule 2 condition used instead of permission was
6(1),
> included here for those of you who, like me, don't have them all
> memorised...
>
> 6 (1) The processing is necessary for the purposes of legitimate
> interests pursued by the data controller or by the third party or
> parties to whom the data are disclosed, except where the processing
is
> unwarranted in any particular case by reason of prejudice to the
rights
> and freedoms or legitimate interests of the data subject.
>
> I'm not too happy that permission wasn't sought anyway, out of
> politeness if nothing else, but hey ho. The thornier issue was when
a
> staff member found this information popping up when doing an online
> search against their name. They reported to me that they had not
been
> informed the information was to go online, and wanted it removed. We
got
> this in writing, treating it as a Section 10 notice, and pulled the
> information off the website while the matter was discussed.
>
> An agreement has not been reached and management are looking to put
the
> information back online as soon as possible, claiming that the
possible
> damage or distress is neither substantial nor unwarranted. The staff
> member has lodged a complaint with the ICO, but the team that will
> probably handle the case has a 4 month backlog.
>
> Cavalier attitude to staff aside, I'd like thoughts on whether the
law
> is being followed in a reasonable manner. Its not best practice, in
my
> opinion, but not having dealt with an issue like this where an
agreement
> has not been reached, I'd appreciate the beenfits of experience!
>
> Thanks
>
> Joe Sutton
> Data Protection Officer
>
>
>
>
------------------------------------------------------------------------
> -------------------
>
> Save Paper - Do you really need to print this e-mail?
>
> This email and any files transmitted with it are confidential and
> intended solely for the use of the individual or entity to whom they
are
> addressed. Any views expressed in this message are those of the
> individual sender and may not necessarily reflect the views of Somer
> Housing Group or its member organisations. If you are not the
intended
> recipient of this message, you are hereby notified that any further
use
> of this message is prohibited and requested to notify the ICT
department
> ([log in to unmask]) at Somer Housing Group immediately.
>
> Somer Housing Group incorporates Somer Community Housing Trust,
Redland
> Housing Association, Bath Self Help Housing Association, Lantern
Homes
> Ltd and Somer Housing Group Ltd.
>
> Somer Community Housing Trust is a company limited by
guarantee,
> registered in England and Wales, no. 3574882 Housing
Corporation
> no. LH4209 Charity Commission no. 1074574
>
> Bath Self Help Housing Association Limited is registered in
England
> and Wales as an exempt charity with the Financial Services
Authority,
> no. 24208R Housing Corporation no. LH3918
>
> Lantern Homes Limited is a company registered in England and
Wales,
> no. 4705482
>
> Somer Housing Group Limited is a company registered in England
and
> Wales, no. 4302179 Housing Corporation no. LH4336.
>
> Registered offices: The Maltings, River Place, Lower Bristol Road,
Bath,
> BA2 1EP Tel: +44 (0)1225 366000, email: [log in to unmask]
>
> Redland Housing Association Limited is registered in England
and
> Wales as an exempt charity with the Financial Services Authority,
no.
> 20903R Housing Corporation no. L0419
>
> Registered office: Holly House, Corbet Close, Lawrence Weston,
Bristol,
> BS11 0TA Tel: +44 (0)117 9382700, email:
[log in to unmask]
>
>
------------------------------------------------------------------------
> -------------------
>
> ________________________________
>
> All archives of messages are stored permanently and are available to
the
> world wide web community at large at
> http://www.jiscmail.ac.uk/lists/data-protection.html
>
> Selected commands (the command has been filled in below in the body
of
> the email if you are receiving emails in HTML format):
>
> * Leaving this list: send leave data-protection to
> [log in to unmask]
> <mailto:[log in to unmask]&BODY=LEAVE%20data-protection>
> * Suspending emails from all JISCMail lists: send SET * NOMAIL to
> [log in to unmask]
> <mailto:[log in to unmask]&BODY=SET%20*%20NOMAIL>
> * To receive emails from this list in text format: send SET
> data-protection NOHTML to [log in to unmask]
> <mailto:[log in to unmask]&BODY=SET%20data-protection%20NOHTML>
> * To receive emails from this list in HTML format: send SET
> data-protection HTML to [log in to unmask]
> <mailto:[log in to unmask]&BODY=SET%20data-protection%20HTML>
>
> All user commands can be found at
> http://www.jiscmail.ac.uk/help/commandref.htm and are sent in the
body
> of an otherwise blank email to [log in to unmask]
>
> Any queries about sending or receiving messages please send to the
list
> owner [log in to unmask]
>
> (Please send all commands to [log in to unmask] not the list or
the
> moderators, and all requests for technical help to
> [log in to unmask], the general office helpline)
>
> ________________________________
>
>
> ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
> All archives of messages are stored permanently and are
> available to the world wide web community at large at
> http://www.jiscmail.ac.uk/lists/data-protection.html
> If you wish to leave this list please send the command
> leave data-protection to [log in to unmask]
> All user commands can be found at
http://www.jiscmail.ac.uk/help/commandref.htm
> Any queries about sending or receiving messages please send to the
list owner
> [log in to unmask]
> Full help Desk - please email [log in to unmask] describing
your needs
> To receive these emails in HTML format send the command:
> SET data-protection HTML to [log in to unmask]
> (all commands go to [log in to unmask] not the list please)
> ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
>
>
>
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
All archives of messages are stored permanently and are
available to the world wide web community at large at
http://www.jiscmail.ac.uk/lists/data-protection.html
If you wish to leave this list please send the command
leave data-protection to [log in to unmask]
All user commands can be found at
http://www.jiscmail.ac.uk/help/commandref.htm
Any queries about sending or receiving messages please send to the
list owner
[log in to unmask]
Full help Desk - please email [log in to unmask] describing your
needs
To receive these emails in HTML format send the command:
SET data-protection HTML to [log in to unmask]
(all commands go to [log in to unmask] not the list please)
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
**********************************************************************************
This e-mail may be read by employees of the Council and is therefore not to be considered private by the recipient. The views expressed in this e-mail are those of the individual and not necessarily the views or opinions of Bracknell Forest Borough Council.
This e-mail and any files transmitted with it are confidential and intended solely for the use of the individual or entity to which they are addressed. If you have received this e-mail in error please notify the system manager. Email: [log in to unmask]
This footnote also confirms that this e-mail has been swept by MIMEsweeper for the presence of computer viruses. Although the Council has taken steps to ensure that this e-mail and any attachments are virus free we advise that in keeping with good ICT practice the recipients should confirm this for themselves.
**********************************************************************
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
All archives of messages are stored permanently and are
available to the world wide web community at large at
http://www.jiscmail.ac.uk/lists/data-protection.html
If you wish to leave this list please send the command
leave data-protection to [log in to unmask]
All user commands can be found at http://www.jiscmail.ac.uk/help/commandref.htm
Any queries about sending or receiving messages please send to the list owner
[log in to unmask]
Full help Desk - please email [log in to unmask] describing your needs
To receive these emails in HTML format send the command:
SET data-protection HTML to [log in to unmask]
(all commands go to [log in to unmask] not the list please)
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
|
