Aren’t paper files exempt from the Data Protection Act – are we OK if we don’t computerise our workers’ health records?
Not necessarily. As well as computerised records manual data held within a “relevant filing system” are covered by the Act. This is defined as any set of data which is structured either by reference to individuals or by reference to criteria relating to individuals in such a way that specific information relating to a particular individual is readily accessible. An example of a relevant filing system would be a personnel file with a worker’s name or individual reference number on it and in which there are internal dividers which make it easy to find information about the worker such as starting date, performance mark at last appraisal, absence record etc. Other examples might be a file of pplications for a particular vacancy in which the individual forms are kept in alphabetical order, or a file of the results of drug tests in which the individual results are kept in alphabetical order. Less obviously structured records, particularly those where the information is kept merely in date o
