21 August 2017 chat with ico_rachels

This page contains the transcript of a web chat we had with a member of the ICO team.

The team members have been really helpful and very gracious in allowing us to publish these transcripts. We are duty bound to point out that the information included will be the view of the agent and could of course be subject to the misunderstandings that can arise from a purely written conversation. The actual General Data Protection Regulation should always be regarded as the ultimate source of truth.

Inital Question: Does collecting data count as processing under GDPA?

[11:15 AM] Tom has joined the room

[11:15 AM] ico_rachels has joined the room

[11:15 AM] ico_rachels has joined the room

[11:15 AM] ico_rachels:

Good Morning, Tom.

[11:15 AM] Tom:

Hi Rachel

[11:15 AM] Tom:

I was looking at 4(2)

[11:16 AM] Tom:

it seems like th e very act of collecting data counts as processing, and so brings you under the GDPA? I'd been thinking of processing as 'doing something' with the data, like an invoice run, or marketing

[11:17 AM] Tom:

but it seems like collection is and of itself processing?

[11:19 AM] Tom:

(sorry, comedy typo GDPR not GDPA..)

[11:20 AM] ico_rachels:

Yes, that's correct. As you will see from the definition under Article 4 (2) this relates to 'collection, recording, organisation, structuring etc.' so collecting personal data is likely to fall within the scope of the GDPR.

[11:2 1 AM] Tom:

It's a slightly unfortunate choice of words in a way, processing sounds like actively doing something *with* the data, rather than just passively collecting it.

[11:22 AM] Tom:

Many thanks for this. I'm putting together a blog/website on GDPR for our customers to try and give them further guidance, is it OK to include a full transcript of this chat for their information? That site is intended as an adjunct to the ICO site, and contains additional clarification and insights for our SME clients.

[11:24 AM] ico_rachels:

You're welcome. Yes, you can use this transcript.

[11:24 AM] Tom:

Thanks Rachel, much appreciated. Signing off for now.

[11:26 AM] ico_rachels:

Thank you for using our live chat service today. Have a good day.

[11:26 AM] ico_rachels has left the room

[11:26 AM] Tom has left the room


Important: This site describes our current understanding of the General Data Protection Regulation (GDPR).

We are not lawyers, always seek specialist GDPR advice for your organisation.

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