Just to clarify, the 1911 census has been released early, apart from one
category of data of continuing sensitivity, following a decision by the
Information Commissioner under FOI - not an administrative error.
School records is a live issue with differing views as to what pupil
details can be made available and what should be withheld. Even the name
of parent or guardian or the address can be sensitive in some
circumstances, e.g. as an indicator of whether a child is in care.
Health and disciplinary details could also cause problems.
You may find the code of practice for archivists and records managers
under section 51(4) of the Data Protection Act relevant in relation to
access to older personal information. This is available on various
websites - here is a link to it on ours
http://www.nationalarchives.gov.uk/documents/dp-code-of-practice.pdf
Susan Healy
Information Policy Consultant and Data Protection Officer
The National Archives
Tel 020 8392 5330 ext 2305
Email [log in to unmask]
www.nationalarchives.gov.uk
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of simon howarth
Sent: 02 June 2009 13:49
To: [log in to unmask]
Subject: Re: [data-protection] School Registers
Hi Doreen,
Name and DOB are pretty powerful together, but not necessarily a major
cause for concern. I suppose you have to consider the risks. What are
the risks of someone being distressed or damaged as a consequence of
releasing this information, quite apart from considering the privacy
impact - Privacy Impact Assessment anyone?
I can only compare it (and it's not a good comparison) with the 1939
registers held by the NHS which was the enumeration performed in
September 1939 that was used to issue identity cards and which had all
births, deaths and lots of other information added to it up to 1991 when
it went electronic.
Even though there may be entries where individuals have passed away or
the address is no longer relevant, there is still a chance of people
from 1939 being alive, therefore unless they can be traced and give
their consent the information would not be made public.
I am not sure if such a register would be classed as a public documen
now, and maybe you should check out the relevance of the Public Records
Act to see if this may play a part? Census data and the 1939 enumeration
are covered by the Census Act and there is a 100 year moratorium on the
release of information, with the exception of the 1911 census which was
made public early due to an administrative error.
I suppose, if it were me, I would not be displaying the register, or I
would be redacting all but name.
Sorry, to be of no more use!
Simon Howarth.
Please don't print this e-mail unless you really need to.
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