Hi Simon,
I can see your point but the "Subject" of the email is to classify the email, and may not include biographical information about the data subject whose name is used as the subject of the email (a la Durant as you say!). I think applying the ruling in Durant is important here and is what I would use as my argument if the approach were legally challenged. Interpretation is the devil as usual!
Best wishes,
Michelle
Michelle Peel
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-----Original Message-----
From: Simon Howarth [mailto:[log in to unmask]]
Sent: 09 January 2013 10:16
To: Peel, Michelle; [log in to unmask]
Subject: RE: [data-protection] Addresses being personal data
Hi,
I can understand the view. However, if you look up what "subject" means, "...a person or thing that is being discussed, described, or dealt with". I would suggest that by putting someone's name in the subject line of an email, legally(?) makes that email about the person, whether they are mentioned again or not. The implication is that the person's name in the subject means that the email is "about" them, regardless of the personal nature or not of the content. If the email is headed "Meeting to discuss SH" as opposed to Simon Howarth then the personal identification is removed and I would be inclined to agree with you, but by making the email "about" a person, then I would say the information is personal. Disclosure would then be subject(!) to exemptions/conditions.
Simon Howarth MSc. MBCS CITP
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Michelle Peel
Sent: 09 January 2013 09:34
To: [log in to unmask]
Subject: Re: [data-protection] Addresses being personal data
Morning,
Interestingly I would take the opposite approach to Simon! When we've had to trawl emails for personal data for DSARS I have taken the view that the email has to be "about" the data subject in order to count. So emails which have the subject line of "Jane Bloggs" but the content is about "are you free for a meeting to discuss this case" etc. would not count, unless there was something about "Jane Bloggs" also in there e.g. "can we reschedule this meeting as Jane Bloggs is still off sick."
So to answer your question brenda, I would discount any emails which are staff arranging time to visit the properties, unless there is something which is "about" the data subject in there too.
Best wishes,
Michelle
Michelle Peel
CYPS Information Governance Officer
Trafford Council
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