So far as I recall none of the places I have had detailed involvement with have ever done this for students / employees etc.
IMO you can cover this under Art 14(5)(b) disproportionate effort since the number of instances where a NOK / EC would really object is very small since:
1. The concept is one most people are familiar with and it would not cause any surprise
2. It would be within the reasonable expectation of the NOK / EC in most cases
3. It is reasonable to assume that the student / employee will give a sensible response and can tell the NOK / EC - particularly if prompted
4. Being named is not a significant infringement of anyone's privacy
5. Most reasonable people would think you were barking mad for wasting time and (possibly if by post) money telling them something so obvious and trivial (possibly this one not a reason to be recorded)
To use 14(5)(b) you should:
1. Document your reasons and decision
2. When collecting ask the giver to tell the NOK/ EC and let you have an alternate if there are any objections
3. As part of the required "appropriate measures to protect the data subject’s rights and freedoms and legitimate interests" ensure access to and criteria for use of the data is strictly prescribed and controlled and
4. Publicise this in some way on your website via your general privacy notices
If you do all that the prospect of any significant regulatory sanction is close to zero, even if ICO ultimately disagreed following a valid complaint.
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
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 https://www.jiscmail.ac.uk/help/subscribers/subscribercommands.html
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)
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
|