According to the Data Protection Act personal data means
data which relate to a living individual who can be identified –
(a) from those data, or
(b) from those data and other information which is in the possession of, or is likely to come into the possession of, the data controller,
and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.
Where the ability to identify an individual depends partly on the data held and partly on other information (not necessarily data), the data held is still “personal data”.
It is also very important to remember that the definition also specifically includes opinions about the individual, or what is intended for them. This could apply to notes made at an interview or a managers assessment of an individual at the end of their probationary period.
If you have concerns about compliance with the Data Protection Act our Data Protection MOT may be just for you. Read more…