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For externals, we at UEA are thinking about the issue of membership renewals as a result of this query, though on the whole, since externals have for some years now only been granted membership if they supplied us with an e-mail account, personally I think it's self-evident that they have opted in, and that we have met the ICO's 'bar' for existing consent not requiring renewal, i.e.

"You do not need to automatically refresh all existing consents in preparation for the new law. But the GDPR sets the bar high for consent, so it's important to check your processes and records to be sure existing consents meet the GDPR standard. If they do there is no need to obtain fresh consent."

(from https://iconewsblog.org.uk/2018/05/09/raising-the-bar-consent-under-the-gdpr/)

In terms of everyone else: our DPO has advised us that the ICO has indicated that (subject to the final act* not making changes to definitions) it views universities as generally operating under the legal basis of 'public interest', specifically public authorities doing their necessary work, so consent is not an issue, and I see entries on the ICO web pages (especially the buff-coloured section on https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/#ib3) that supports this. Anyway, staff and students here are required by university regulations to use their university e-mail account.

* still not passed, it seems.

Alan

==============================
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Systems/Databases Librarian.
The Library,
University of East Anglia,
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From: A general library and information science list for news and discussion. <[log in to unmask]> On Behalf Of Tracey Stanley
Sent: 18 May 2018 08:48
To: [log in to unmask]
Subject: Re: GDPR sign-up from existing members

Hi,

We are just handling this through renewal when memberships expire.  I assume we are just talking about external memberships here rather than our staff and student body who will be covered under broader University arrangements.  We do have automated renewals but I'm not aware that we've had an external members decline to provide an email address.

Would be interested to see if there is a different consensus on what we should be doing, as maybe I should be raising it with our Data Protection Officer!

Tracey


From: A general library and information science list for news and discussion. [mailto:[log in to unmask]] On Behalf Of Jane Mansfield
Sent: 17 May 2018 16:42
To: [log in to unmask]<mailto:[log in to unmask]>
Subject: GDPR sign-up from existing members

Can I please ask what other libraries are doing in terms of GDPR opt-in from existing users?

We have a process for new members, who join our library as of now, but have existing members for whom this process wasn't in place when they joined.

I'd be interested to know how your library is handling the GDPR opt-in:

*         If you have reference users, are you expecting them to opt in now, or just to opt in, or choose not to extend their membership, when their current period of membership expires and they come in to renew?

*         How long have you given users to get back to you to confirm their expression of interest?

To add to the fun we're moving to auto-renewals this summer so will need borrowers to agree to receive emails going forward or they will no longer be able to borrow as we won't otherwise be able to quickly notify them that an item can't be renewed.  If you have auto-renewals, do you have any users who declined to provide you with an email address (we currently have a handful who haven't provided us with one) and how did you handle that?

Thanks,

Jane

Jane Mansfield
Senior Assistant Librarian (Service Development and Delivery), Library and Learning Services

DE MONTFORT UNIVERSITY
Leicester LE1 9BH
T: +44 (0) 116 207 8376
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W: dmu.ac.uk