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DOES THIS APPLY TO PAPER DOCUMENTS?
Yes, the de nition of “data” includes information that is “recorded as part
of a relevant ling system or with the intention that it should form part of
a relevant ling system”. Depending upon how well organised your manual records are, they may fall into part of a “relevant ling system”, but each situation has to be looked at on the individual facts. As a rule of thumb, if you have some sort of recognised ling system, where someone without any prior knowledge of the system could access information relating to a particular individual, then any manually held records in that ling system will be covered by the DPA.
WHO IS RESPONSIBLE FOR COMPLIANCE WITH THE DPA?
You are!
The question is slightly more complicated under the legislation, as it depends upon who is the “data controller”. The data controller is the organisation that controls what happens to any personal information that is held. It is not an individual within the organisation, and although some organisations do have a named individual, it is the organisation as a whole that is responsible (meaning, for your purposes, the trustees).
There can be more than one controller for the same set of information, and the “control” can be as simple as deciding what to collect, or to whom it should be disclosed. You will be a data controller for any personal information that you hold and use, but be aware that you may also come to be a data controller in respect of information shared with you by others (for example social services and other statutory agencies). Where this occurs, you are responsible for ensuring that information is secure and kept in accordance with the principles set out below.
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