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Data protection query?


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Now I may be wrong about this.

Arrived on a CL site today.

On the notice board are all the booked in arrivals full names and dates of arrival and departure, as well as pitch number.

Now is that sort of information actually allowed on public display?

 

Edited by PR1

2019 Bailey Platinum (640) Phoenix from Chipping Sodbury caravans, towed by our  2017 my Discovery Sport!

 

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I always think of Data Protection as protection of data held on a computer. It would be difficult for some CL's to operate without doing what you have noted as the owners are not always on hand to personally give you the information.  Now I suppose they could email the information to you but given that not all CL owners and certainly some of their customers are tech savvy that might not work. On the point about public display surely it is only on display to those using the CL rather than being in the full public domain? What might be a better way of doing it would be to have the information in an envelope which each person takes as they arrive but even then your full name will be visible until you collect it.

 

David

David - Milton Keynes

Bailey Alliance 66-2 Motorhome for holidays and a Kia Venga for home.

 

Caravan Travels

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Nothing wrong with a list of names. 

Graham

Unless otherwise stated all posts are my personal opinion 

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Data protection legislation applies to all methods of collection, storage and management and has never been specific to computerised systems. It equally applies to things like manual card indexes.

 

A name on it's own may not be considered as personal data under the GDPR. Context is everything and names aren’t always considered personal data under the legislation. However, where the name is combined with other information (such as an address, a place of work, or a telephone number) this will usually be sufficient to clearly identify one individual and then be considered to be personal data.

 

Therefore, to answer the OP's question, displaying a name with two dates and a pitch number is insufficient to clearly identify an individual and does not appear to breach data protection legislation.

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Might be different if it also displays contact numbers, of course.

 

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1 hour ago, PR1 said:

Now I may be wrong about this.

Arrived on a CL site today.

On the notice board are all the booked in arrivals full names and dates of arrival and departure, as well as pitch number.

Now is that sort of information actually allowed on public display?

 

One benefit, it makes it easy to get to know your new neighbours by name and also if you do not like them, you will know when they are leaving.

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I'm not sure about this. I think for them to run the business this might be a necessary tool. What I dont agree with is public being able to see this. 

Would you want your campsite neighbour wanting to know your name prior to even meeting you just because they had a sneaky peak? Might not be a breach of GDPR but is it morally correct? 

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From the notice board a person can obtain a name and a pitch number, they could then visit the pitch and identify the vehicle registration number of the car, which when linked to a name can be used to identify a person.

Jaguar E-Pace 180D HSE R Dynamic - 2008 Swift Conqueror 540

 

"Unless otherwise stated, my posts will be my personal thoughts and have the same standing as any other member of Caravan Talk"

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13 minutes ago, smith100s said:

Would you want your campsite neighbour wanting to know your name prior to even meeting you

That a name is visible on a board doesn't mean that all and sundry will actually read the names, let alone want to know them.

 

Personally I would neither know or care, I suppose that is no different to the old, and still used on some sites, practice of putting a stake with the next incumbents surname on the pitch, to which I have seen over the years, the occasional odd folk camping on the site, wandering around reading the names, for whatever reason.

 

I would think it very odd anyone approaching me saying " Hello Mr. X, how long are you staying, or whatever " but if they knew my first name from talking to say another camper or the site owner and said " Hi ( first name) I'm Steve, how long are you staying  " no problem.

 

When all said and done, there are far more important things in life to worry about or ponder over, than such trivia or minutiae as who knows your name, especially when on holiday.

 

 

Common sense isn't a gift, it's a punishment because you have to deal with everyone who doesn't have it.  :rolleyes:

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57 minutes ago, Grandpa Steve said:

and identify the vehicle registration number of the car, which when linked to a name can be used to identify a person.

To what end ?

 

But only under very specific DVLA rules, such as car park operators or a private individual if they suspect that a particular vehicle has caused damage to property or persons, obviously police etc. excluded.

 

The info will only show the registered keeper and address not the owner or driver of the vehicle, nor their addresses, which could be two or more different people or entities.

 

If the registered keeper, when contacted says " No idea who was driving at that time or date "  the job stops.

 

I think that worrying about someone coming on to a site, to enjoy a two week holiday, who will then go on to note one or more names on a notice board, note their reg. numbers then go through the DVLA process, for whatever reason, is in the realms of fantasy.

 

But we have to admit, recognise and accept, that there are many odd and unusual, but possibly harmless folk, at loose in the world, who could fall into these categories.

 

Such is the realms of novels and true life stories, as the saying goes, " Truth can sometimes be stranger than fiction. "

 

 

 

 

Edited by Silversurf

Common sense isn't a gift, it's a punishment because you have to deal with everyone who doesn't have it.  :rolleyes:

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I see no benefit to anyone other than staff seeing this information. I take on board your points silver surf but at the same time unless I gave my name to someone willingly I wouldn't expect a business to openly display it without my permission. 

 

Whilst personally I couldn't give a toss I also know working in customer services that many customers are very sensitive about their data and how it is stored and many business go to huge lengths and expense to protect their customer data.  Therefore I stand by the view that non staff don't need to see this information. 

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49 minutes ago, smith100s said:

unless I gave my name to someone willingly I wouldn't expect a business to openly display it without my permission. 

 Therein lies the solution to your, and anyone else with the same perceived perception of data protections problem, who may not want their name displayed on a sites office notice board, which Legal Eagle has said complies totally with and doesn't go against the data protection act.

 

1) You have obviously given your name willingly when booking, presumably having read and understood all the sites info ?

2) If you don't want the site, or any where else, to have your name and pitch number publicly displayed on the board, which may be an integral part of the sites business model and security protocol, then before booking ask if there is a way it can not be displayed.

 

The site may also maintain the board list as an easily accessible means of identifying residents, for such as Covid or emergency services intervention.

 

Mountains and molehills spring to mind. 🤷‍♀️

 

 

 

 

Common sense isn't a gift, it's a punishment because you have to deal with everyone who doesn't have it.  :rolleyes:

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firstly, why was the list of names displayed in the first place?    Did you query it at the time? 

 

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If you walk past the the front of my van our names are displayed on a plaque which also states where we used to live.

 

Ian

2018 Range Rover Sport AB,  2015 Buccaneer Cruiser.

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With a lot of CL’s being “unmanned” stating the persons name & allocated pitch number on a board is a simple and effective way of controlling allocation. I’m all for protecting peoples data but sometimes it seems folks want to push it beyond it’s workability. What next? Footballers demanding their names are removed from their shirts?

2018 Volvo V90 and 2018 Swift Sprite Quattro EB

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Given the way people seem to willingly give out information on Facetwit and other platforms i cannot get excited about this. Another example of unintended consequencies of ill thought through legislation. 

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9 hours ago, Silversurf said:

Personally I would neither know or care,

When all said and done, there are far more important things in life to worry about or ponder over, than such trivia or minutiae as who knows your name, especially when on holiday.

 

I agree

 

8 hours ago, Silversurf said:

I think that worrying about someone coming on to a site, to enjoy a two week holiday, who will then go on to note one or more names on a notice board, note their reg. numbers then go through the DVLA process, for whatever reason, is in the realms of fantasy.

 

I agree

 

6 hours ago, Silversurf said:

Mountains and molehills spring to mind. 🤷‍♀️

 

I agree.

 

I also agree with your signature line about Common Sense. I am Chairman of a local Village Hall and we have recently been sent a 49 page document about how to reopen safely with the necessary Covid precautions - I was about to give up the whole thing when I saw the following 'Common Sense can be applied' !!

 

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8 hours ago, Silversurf said:

To what end ?

 

But only under very specific DVLA rules, such as car park operators or a private individual if they suspect that a particular vehicle has caused damage to property or persons, obviously police etc. excluded.

 

The info will only show the registered keeper and address not the owner or driver of the vehicle, nor their addresses, which could be two or more different people or entities.

 

If the registered keeper, when contacted says " No idea who was driving at that time or date "  the job stops.

 

I think that worrying about someone coming on to a site, to enjoy a two week holiday, who will then go on to note one or more names on a notice board, note their reg. numbers then go through the DVLA process, for whatever reason, is in the realms of fantasy.

 

But we have to admit, recognise and accept, that there are many odd and unusual, but possibly harmless folk, at loose in the world, who could fall into these categories.

 

Such is the realms of novels and true life stories, as the saying goes, " Truth can sometimes be stranger than fiction. "

 

 

 

 

i would expect that most registered keepers are also the owners.

macafee2

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This (below) seems quite a good relevant example of this issue regarding publishing student exam grades - likelihood  is in the OP the owners just won’t even have given it a thought (or even be aware) and for the majority who stay I doubt they worry either. That’s not to say that’s a reasonable excuse (ignorance, however innocent). I bet they’d write down credit card details too without a moments thought (or worse still keep them on file!). 

 

Displaying personal data on notice boards

As a rule, personal data should not be posted on a public notice board, especially if it constitutes special category data. However, the Information Commissioner’s Office accepts that publishing exam pass lists in this way is a long-standing practice and may be allowed to continue. It is important to note though that any student who objects is entitled to have their name removed from the lists.

In order to ensure compliance with the first principle of the General Data Protection Regulation we must ensure that personal data is processed fairly, lawfully and in a transparent manner. Students must therefore be informed of the means where their examination results will be made available to them and, if it involves public disclosure, given the opportunity to object and ask for an alternative means of notification.

 

Cheers, Martin

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9 hours ago, Silversurf said:

To what end ?

Quote

Is a car registration plate my personal data?

The answer to that question is: yes, a car registration plate is personal data if the car is owned by an individual or sole trader. The registration plates of commercial vehicles are not personal data of an individual as the vehicle is owned by an organisation.

The reasoning is as follows:

The GDPR and the Data Protection Act define personal data as: “any information relating to an identified or identifiable living individual”.

 

An identifiable living individual is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the individual.

 


The ICO States

 

What kind of information could allow an individual to be indirectly identified?

The following is a non-exhaustive list of information that could constitute personal data on the basis that it allows for an individual to be singled out from others:

car registration number and/or VIN;

national insurance number;

passport number; or

a combination of significant criteria (eg age, occupation, place of residence).

 

The key point of indirect identifiability is when information is combined with other information that then distinguishes and allows for the identification of an individual.

Jaguar E-Pace 180D HSE R Dynamic - 2008 Swift Conqueror 540

 

"Unless otherwise stated, my posts will be my personal thoughts and have the same standing as any other member of Caravan Talk"

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I really don't think this is anything to get worked up about and I'm sure the CL owners are only displaying names so people arriving can identify their allocated pitch if the owners are not available (pitch allocation is another issue we'll ignore for now!). If someone is really concerned about their name being displayed they could asked that an anonymous reference is used for the display instead of their name which would serve the same purpose.

Life is not a rehearsal . . .:)

Porsche Cayenne S Diesel & Knaus StarClass 695. Previously Audi S4 Avant & Elddis Super Sirocco

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If it is just the name and no other personal details then there should be no problem. The CAMH used a similar system at Black Horse Farm for late arrivals basically John Smith pitch no and that was it for you to pitch. That is not enough to be of any use to anyone and contains no personal data, so here is no problem there.

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22 hours ago, Wildwood said:

If it is just the name and no other personal details then there should be no problem. The CAMH used a similar system at Black Horse Farm for late arrivals basically John Smith pitch no and that was it for you to pitch. That is not enough to be of any use to anyone and contains no personal data, so here is no problem there.


Source - ICO ”How do we identify someone indirectly?

It’s important to be aware that information you hold may indirectly identify an individual and therefore can still be personal data. If so, this means that the information is subject to the UK GDPR.

If you cannot identify an individual directly from the information that you are processing (for example where all identifiers have been removed) an individual may still be identifiable by other means. This may be from information you already hold, or information that you need to obtain from another source. Similarly, a third party could use information you process and combine it with other information available to them.”

You must carefully consider all of the means that any party is reasonably likely to use to identify that individual. This is important because you could inadvertently release or disclose information that could be linked with other information and (inappropriately) identify an individual.

 

What kind of information could allow an individual to be indirectly identified?

The following is a non-exhaustive list of information that could constitute personal data on the basis that it allows for an individual to be singled out from others:

 

So the information on the CL’s notice board can be combined with the information from the vehicle and be used to identify an individual

 

Jaguar E-Pace 180D HSE R Dynamic - 2008 Swift Conqueror 540

 

"Unless otherwise stated, my posts will be my personal thoughts and have the same standing as any other member of Caravan Talk"

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On 21/04/2021 at 21:00, Legal Eagle said:

Data protection legislation applies to all methods of collection, storage and management and has never been specific to computerised systems. It equally applies to things like manual card indexes.

 

A name on it's own may not be considered as personal data under the GDPR. Context is everything and names aren’t always considered personal data under the legislation. However, where the name is combined with other information (such as an address, a place of work, or a telephone number) this will usually be sufficient to clearly identify one individual and then be considered to be personal data.

 

Therefore, to answer the OP's question, displaying a name with two dates and a pitch number is insufficient to clearly identify an individual and does not appear to breach data protection legislation.


Source ICO

“‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

Jaguar E-Pace 180D HSE R Dynamic - 2008 Swift Conqueror 540

 

"Unless otherwise stated, my posts will be my personal thoughts and have the same standing as any other member of Caravan Talk"

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This is just my personal opinion but all information held by a campsite (or similar) should not be placed where it can be read by anybody not authorised to see it. Thus, even a surname and a pitch number really should be held at reception for staff use only, and not placed where any other visitors can see it.

I can see a potential issue here when signing in at reception if a common book is used for all visitors, where a glance up  the page could reveal the names of other visitors, possibly with their vehicle registration numbers and pitch allocation - or are we just becoming paranoid over our personal details these days?  

Where there is a legitimate, even beneficial, reason for sharing details with others then I have no issue with that.

Fourwinds Hurricane 31D Motorhome. Also MGTF135 1. 8i Roadster (fun) & Volvo V70 3.2Ltr LPG (everyday car)
Unless otherwise stated, my posts will be my personal thoughts and have the same standing as any other member of Caravan Talk.

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