FOIMan finds DP being breached in his own backyard.
Back in 1936, the Crystal Palace, originally built for the Great Exhibition in 1851, and later moved to parkland to the south-east of London, burnt down. It had been in decline for many years, so there was no rush to rebuild it. Indeed, nearly 80 years on, its site still stands bare, save for a few sphinx, crumbling steps and headless statues.
One of the reasons that it has remained that way is that local residents kind of like it. There is a romantic air about the site, and the lack of a central attraction means that its surrounding parkland is a nice place for a quiet stroll, occasionally interrupted by a dinosaur. It’s our little secret.
So there are a few raised eyebrows in this suburb of south London at Boris Johnson’s excited pronouncement last year that a Chinese investor, Zhong Rong International (Group) Ltd, wants to rebuild the Crystal Palace. And keen to drum up community support the consultants coordinating the project, Arup, have arranged a series of drop-in sessions where locals can ask questions and complete a questionnaire about their views on what should be built (or indeed whether anything should be built at all).
Mrs FOIMan and I are sceptical about the plans so we decided to pop along to today’s session. The first thing we were asked to do was to add our name, address and email address to a sheet by the door. Mrs F, on the ball as ever, asked why they were collecting the information. The slightly flustered looking lady on the door answered:
“It’s just so we can write to you with updates, that sort of thing.”
Needless to say there was nothing on the sheet to explain this and it wasn’t volunteered. The lady at the door just asked each person who arrived to fill in their details as though it was a requirement of entry.
After we’d chatted to the staff from the Greater London Authority (Boris’s HQ, and my former employer) and Bromley Council we dutifully completed our questionnaires. Before asking about the plans, it asked for some personal information. It explained this time that we didn’t have to give this, but that it would be used to contact us with updates on the plans. Which is fair enough. Except that apparently they needed our gender, ethnicity, and age group to contact us.
Now if you’re trying to reassure a sceptical public of your plans, collecting their details unfairly (ie without telling them what you’re going to do with it) and breaching at least two data protection principles in the process (1 and 3 as you ask) probably isn’t the best way to do it. As more high profile projects have found, this kind of thing can come back to bite you. And it doesn’t exactly smack of a professional, well-run operation.
We completed it anyway (apart from the data that they had failed to justify) and left. On the way out Mrs F turned to me and said “Damn, I wish I’d made a copy of my questionnaire”.
I considered this and replied helpfully:
“Well you could always make a subject access request…or at least you could have done if they’d told us who the data controller was.”
If you want to know how to collect personal information fairly, why not book on my Practical DP course through Act Now Training?