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Marketers are full of creative ideas and regularly think up new ways of using the personal data they control. At times this “re-purposing” of data pushes the boundaries of what might be obvious to the data subjects themselves and that’s where problems arise.

Information Commissioner, Chris Graham has recently spoken out about public authorities’ use of credit referencing information for the prevention or detection of benefit fraud. Whilst the unforeseen data sharing might be regarded as re-purposing, Graham takes the common sense approach:  “It is reasonable to expect that if you are committing benefit fraud your details will be shared with the appropriate authorities dealing with this. But any information sharing should be made clear in privacy policies.”

And there’s the rub for those creative marketers: Do the privacy notices they currently use fully inform individuals or are the statements unclear about the consequences of handing over data?

In the commercial list world, data is increasingly being consolidated and then wholesaled for purposes which go well beyond marketing. These purposes include debt collection and use in free personal search engines (a stalker’s dream). Hardly something the average punter would have in mind when filling in a lifestyle questionnaire and often not made clear in the small print provided.

It’s not just public sector data sharing which interests the ICO, so data collectors interested in pursuing best practice might be well advised to examine their privacy notices now.



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