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I would have thought that the governance around a joint list will depend on what other agreements are already on place, but, assuming you are both data controllers then a data sharing agreement would be the way to go.
 
In terms of informing individuals, the short answer is "yes", but I suggest you look at the ICO guidance.
 
Donald Henderson
Information Compliance Manager
Perth and Kinross Council


From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Jaines, Amy
Sent: 09 June 2011 14:56
To: [log in to unmask]
Subject: [data-protection] Cautionary Contact List

Good Afternoon,

 

I’m pretty sure I can answer my own query here but would be very grateful of a second opinion.

 

I am in the process of reviewing the protocols around access to our Cautionary Contact List (list of members of the public who have identified as violent/aggressive towards members of staff). Recently we have outsourced our back-office services to newly established ALMO, which include Customer Services and Revenues & Benefits.

 

What we would like to do is to establish a joint Cautionary Contact List which can be accessed by members of staff from both organisations. What I’m wondering is whether or not just an information sharing agreement signed by a representative of both organisations is sufficient for sharing this kind of information?

 

Also, once someone’s details are placed on the register do we have to tell them that we will be sharing that information with another organisation other than the Council?

 

 Many thanks,

 

Amy Jaines - Information Governance Officer

 

Information Management

East Lindsey District Council,

Room 158, Tedder Hall, Manby Park, Manby

Louth, Lincolnshire, LN11 8UP

 

Tel: 01507 329413 ext. 506

E: [log in to unmask]

Website: www.e-lindsey.gov.uk  

 

'Lincolnshire's Coastal District'

 


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