ABSTRACT

Further, you need to think carefully if you subsequently spot an opportunity to use data for a Purpose it wasn’t originally acquired for. The Act says that any use of the data must be ‘compatible’ with the original Purpose(s). If you decide to make use of the data for some new activity, it would be unwise to do this without ensuring that the Data Subjects know as soon as possible of the new Purpose. The further away from the original Purpose(s) this new activity is, the more important it is to ensure that the Data Subjects know what is going on, and that your processing is ‘fair’. This may well require you to give them the opportunity to opt out of any secondary use of the data before you use it.