Data Protection Commissioner

[text version]


Fair obtaining – code numbers on anonymous surveys

A research company sent out a survey to named individuals, and requested them to reply to questions on the form and to return it anonymously. However, the prepaid envelopes bore unique four digit numbers, suggesting that the survey was not in fact anonymous. This raised concerns that personal data were being unfairly obtained, contrary to section 2 (1) (a) of the Act.

A meeting was held with the company. They explained that the numbers on the envelopes were used to check who had responded and to send reminders to those who had not. Once the replies were taken out of the envelopes there was no way of connecting them with any identifiable individuals. Furthermore, replies to the questionnaire were collated in statistical form, from which no individual could be identified. The question of unfair obtaining of personal data did not arise.

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