Data Collection Sheets

[jmak]

What's your agreement with your DPO / SLT's view of them? Is their word law or are they making recommendations? If you discuss your concerns, including the logistics of proving you have consent from someone for whom you only have a phone number, would they consider revising their advice?

 

The DPO has clearly stated that what she says is only advice - but realistically if we go against it, we need to have properly thought about the reasons.

 

Having spoken to SLT, we are going to proceed on the basis that consent is not needed, but we are going to put a statement on the form that the person completing the form must inform the third contact that they have provided their details and that they will inform us if they need to change it.

 

We appreciate that this is not informed opt in consent from the data subject and we are relying on the person giving the data to inform the data subject. We'll have to argue the case that the child's needs outweigh anything else if anyone objects.

[Ketlane]

Beware separated and estranged parents where there may be court orders preventing disclosure of mother's address etc to father and vice versa; this can get very complicated with half siblings and can go horribly wrong. I've had one very near miss - might have triggered a violent incident between the parents and might well have been contempt of court on our part, just prevented the document being posted. Tightened up procedures after that with quite scared secretarial colleagues!

My record number of contacts is seven, all quite reasonably needed, and no separations/remarriages/etc involved!