Hi, Alex. This is also suggested in case law of the European Court of Justice, which also considers less explicit information, such as recordings of work times which include information about the time when an employee begins and ends his work day, as well as breaks or times which do not fall in work time, as personal data. The GDPR: Legitimate interest – what is it and when does it apply? Many thanks. Also, you should ensure that you are deleting these some time after the work with the contractor has ceased. have customers been told that their contact details (i.e. Some of them only remove email addresses and contact numbers of colleagues/employees but retain names and titles whilst others do not redact these details at all, citing that as the colleagues/employees identified were acting in an official capacity their details should remain unredacted so as to ensure transparency and accountability. I wrote an email of complaint to the manager of a members only golf club (but the public can access it for social activities) and it was discussed and minuted in a directors meeting. We keep family records and the children’s registration and attendance records in our system. All the emails to me and from me? For example, if a medical dataset contains the patients’ name, hometown, and medical diagnosis, then a record (or “row”) within this dataset is personal data if the patient who this record is about can be re-identified, meaning that anybody who has access to this dataset is able to associate the record with the patient. These letters have a the person’s name, my address, reference numbers and what is owed by this person. In certain circumstances, someone’s IP address, hair colour, job or political opinions could be considered personal data. Yes, John, it would still be considered personal data as the record refers to individuals who are or can be identified. Many of us do not know the names of all our neighbours, but we are still able to identify them.”. Right to portability Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social … Thus, where bookkeeping records allow to identify an individual, they have to be processed in line with the requirements of the Regulation. Hey Luke, i hope you can help me with this question. Learn how your comment data is processed. In a private tennis club with an online court booking system available ONLY to members, would it transgress GDPR to show the names (and no other information) of those booked to play at a given time? You can’t use consent between an employer and employee, but legitimate interests should suffice. However since Companies House uploaded information about director’s past and present highly sensitive information (Name, DOB, home address, signatures) to their website with no prior risk assessment a few years ago, it has led to numerous instances of identity fraud, stalking, cyber crime and other security risks as well as potential age discrimination for jobs etc. I.e. I am getting that type of information written in such an ideal means? very nice! Can you use one of the above lawful reasons for why you need to obtain the certificate? I think its a very good idea to use the App Protection policy that you have suggested. Basically, a person obtains this capacity with his birth, and loses it upon his death. The GDPR clarifies that this applies whenever an individual can be identified, directly or indirectly, “by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”. When the data subject has given consent to the processing of his or her personal data – you must be able to prove that you have his/her consent. For example, by revealing the first part of the postcode hackers aim to obtain the full postcode or by revealing the flat/house and street name they aim to collect the missing information i.e. Your next step would be to lodge a complaint with the organisation’s supervisory authority — i.e. To make sure that your processing is lawful, you need to: Encryption also obscures information by replacing identifiers with something else. This does not mean that you have to delete or redact the records, however, you need to inform the individuals about how their data is being pocessed (e.g., in the privacy notice), ensure that it is stored securely and kept no longer than necessary. Once I collect these email addresses, I want to add them to the newsletter of my band because I think it could be of their interest. Personal data is any information that relates to an identified or identifiable living individual. Is this allowed, bearing in mind the reviewer has responded to an invitation to provide a review! one’s racial or ethnic makeup; political stances This is often so they can game the system and ensure that they do not dip below 80%. I am currently working in a project where we need to process some information extracted from a Hospital Information System (the information is provided by the Hospital itself). 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