In our draft statement on dp which we intend to link to all websites which
collect personal data, I propose drawing attention to the restriction
created by the 8th principle but also say that because transfers over the
internet may take place potentially to any country in the world, that if
internet facilities are used, that consent to such transfers are implied.
I asked the DPRO what they thought and got the helpful reply that assuming
that consent to a transborder data flow is required, then we must ensure we
get it! The advice did go on to say that this might be through a
notification provided on electronic forms.
This suggests to me that nothing positive is required by the individual (&
their option is to use alternative means to the internet).
Any thoughts?
Gail Waters
DP Coordinator
Open University
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