Surely, they're making it up as they go along. My understanding is that the Data Protection Act is only concerned with the control of and subject access to, personal data, which is processed, and part of retrieval or filing system, or part of an accessible public record and for which the data controller can charge a fee.
So when does the guidance become personal data and since when is it permissible to have the power to charge a fee for such material.
And not even by the wildest stretch of the imagination could it be said that the scribbling down of a punter’s name and address by an IR worker is part of a retrieval or filing system and definitely not part of an accessible public record (this has a very restricted definition).
And even if the Data Protection Act could be interpreted in this way this is surely not what Parliament intended in passing the Act.
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