That is an interesting set of questions and matches similar thoughts to my own.
I just don't think it is reasonable to expect us to re-issue privacy notices to everyone for everything, even when the information came from the subject. On the other hand, I think it is very important to notify people that the legal basis has changed, e.g. from consent to a public interest task, as soon as practical because that actually changes things for them.
At the moment, however, I am holding on to see what the ICO is going to produce next month for informing the public, customers, service users, etc.
Donald
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Phil Bradshaw
Sent: 05 February 2018 09:29
To: [log in to unmask]
Subject: [data-protection] Privacy Notice Revalidation
Under GDPR we will have to re-validate existing consents if they were not obtained in a way which would conform to the stricter requirements of GDPR - Recital 171.
What about mandated Privacy Notice Information? There are some technical requirements e.g. legal basis, retention issues, right to complain to ICO which will not have been in most historical notices.
Do we have to re-issue a PN to existing customers on 25 May? If not is continued processing unfair?
For info not received from the subject we may have the disproportionate effort exemption, but what about info received from the subject? Are we forgiven because Article 13 only bites at the time obtained?
If so does it bite again as soon as we obtain further information after 25 May?
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