Medical secretaries and support workers in the NHS would fall under the definition in Part2/Ch2/S11(1) so are no different to Health Professionals in respect of the legislation.
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From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Phil Bradshaw
Sent: 10 October 2018 11:49
To: [log in to unmask]
Subject: Re: [data-protection] Subject Access Requests - third party?
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Forget "health worker".
That term appears in the heading of para 17 of DPA18 Schedule 2 but is not part of the Act* and is not defined.
The term you need is "health professional" and is defined in s204. So those admin staff are not covered by para 17 and in general should not be disclosed** . Even under GDPR Art 15(1)(c) it would be sufficient to refer to admin staff and medical secretaries as categories of recipient rather than naming individually.
* s1 Interpretation Act 1978 "Every section of an Act takes effect as a substantive enactment without introductory words."
** Probably not personal data of applicant and therefore outside scope of SAR and disclosure would be a clear breach. If it is PD then still no need to disclose when you apply the test in para 16 (to which para 17 does not apply in this case as explained above)
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