Comments from Phil Quincey:
> Comments received from Mike Lloyd:
>
> >Finally, it cannot be stressed too highly,
>
> >ANY NEW SYSTEM FROM 24/10/98 WILL BE SUBJECT TO THE TERMS OF THE NEW ACT
>
>
> Dont really understand why you say 'new system', since the current act
> doesn't relate to 'systems' but to 'purposes'. Are you interpreting
> 'processing' in the new act to equate to 'system' ? Hence any user
> replacing the software package they use for, say, Personnel records, would
> be deemed to be processing anew, even if their actual use, content etc of
> the personal data held was exactly the same ?
>
> I have understood 'processing' to mean the purposes currently registered.
> Do others think that an error on my part ?
>
> Regards, Phil
>
>
>
The new Act uses the phrase "relevant filing system" as well as
"processing".
N.B. Processing has a much wider definition than under the 84 Act.
I wished to draw attention to the point if you do something new from
24th October, the new law will apply.
It is not clear ( to me!) how much change to current systems ( e.g
Student Record System) can take place before becoming no longer exempt in
phase 1.
Anyone wish to comment on that?
Mike
>
>
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