NEWS: Scientology snared by new UK law? By Chris Owen

NEWS: Scientology snared by new UK law?
Chris Owen
29 Feb 2000

Tomorrow the Data Protection Act 1998 comes into force in the UK, introducing a radically strengthened set of data protection laws. This brings the UK into line with the European Commission's Data Protection Directive, which establishes a common set of data protection rules across the EU. It also effectively bans the transfer of sensitive personal data to the US, since American data protection laws are much weaker. (I should add that it looks likely that a compromise deal will be reached involving US firms exchanging data with Europe voluntarily agreeing to apply European rules to their activities in the US).

This has important implications for Scientology. It has already fallen foul of the data protection laws - if I remember correctly, it was fined in 1991 for breaches of the old law. The new law is much tougher. It applies to all data processors, private and public, and to paper records as well as electronic ones. It imposes higher standards on data processors and provides extensive rights of scrutiny to those on whom data is held. Its penalties are extremely tough - criminal prosecution and unlimited fines.

Scientology appears to have realised very late in the day that it faces real danger from the new laws. The Dianetics and Scientology Mission of Bournemouth has been registered as a data processor since 1997 but the main UK Scientology entity, the Church of Scientology Religious Education Center Incorporated (COSRECI, an Australian corporation), only registered in December 1999 - in bureaucratic terms, at the very last minute. It raises the question of whether they have been acting legally up to now, since their data processing activities are exactly the same as the Bournemouth mission. The Scientology Mission of Poole and Narconon are not on the register, meaning that from tomorrow they will most likely be in breach of the law.

The registration of COSRECI details its data processing activities as:

1) Marketing and selling (including direct marketing to individuals)
2) Research and Statistical Analysis
3) Membership Administration
4) Public Relations and External Affairs
5) Personnel/Employee Administration
6) Education and training administration
7) Trading in Personal Information

This differs somewhat from the Bournemouth mission's registration:

1) Personnel/Employee Administration
2) Purchase/Supplier Administration
3) Customer/Client Administration
4) Trading in Personal Information
5) Marketing and Selling (including direct marketing to individuals)

Those familiar with Scientology will notice two major omissions from this list: preclear files, which contain a great deal of sensitive information on members, and OSA files, which - if the GO equivalents are anything to go by - are likely to contain a large quantity of personal information on critics of Scientology.

The sinister-sounding "trading in personal information" category sounds like it might cover OSA information. COSRECI describes it as "The sale, hire or exchange of personal information (whether through the data user disclosing personal information or using it on behalf of a third party)" for the purposes of "the maintenance and distribution, as a business activity, of information or databanks consisting primarily of data about individuals; the use of such information or databanks on behalf of third parties; analysis for management purposes and statutory returns." It is applied very promiscuously - "Current, past, potential employees, trainees, voluntary workers ... recipients, customers or clients for goods or services (direct or indirect) ... account holders ... members, supporters of a club, society, institution ... correspondents and enquirers ... survey respondents, other persons assisting research." It is also directly associated with foreign entities: Church of Scientology International of Los Angeles, USA; Church of Scientology Flag Service Organisation of Clearwater, Florida, USA; Author Services Inc. of Los Angeles, USA [so much for that organisation's separation from Scientology!]; Religious Technology Center of Los Angeles, USA [i.e. OSA HQ]; and New Era Publications APS of Copenhagen, Denmark.

The Bournemouth mission casts the net much more narrowly as involving only "Current, past recipients, customers or clients for goods or services (direct or indirect)". It's not clear why the two organisations list differing scopes for the same activity.

While this particular category *might* cover OSA data collection, I rather doubt that it permits the use to which such information has been put - the Data Protection Act includes stringent guidelines on the permissible use of sensitive personal information, including the requirement that it not be used to cause harm or distress. Quite clearly this strikes at the heart of Scientology's obnoxious policy of making its critics "shudder into silence", as detailed in "Project Squirrel" and numerous other OSA and GO policy documents. Scientology can't claim that such practices are covered by legal or journalistic exemptions granted in the Act; the number of critics which it has sued or blackened in its publications is actually very small, compared to the actual number of critics out there. The policy documents in any case make clear that OSA's activities are directed more towards intimidation rather than litigation.

Preclear files appear to have been omitted entirely. This omission in itself is enough to land Scientology in hot water with the Data Protection Registrar, as the information in those files is highly sensitive and Scientology has a proven record (admitted by the present management and the GO criminals) of using supposedly confidential PC data to smear ex-members. It claims to have cleaned up its act now but still does not allow access to those files. Scientology can't claim priest-penitent privileges for the information on PC files and reports from sec checks, or so-called "confessionals". As the Charity Commission's decision last November on Scientology's application for charitable status made clear, Scientology does not meet the legal criteria for a bona fide religion and in law has the same status as any other corporation. Therefore it will have to apply the same data protection rules as any other corporation. From tomorrow, preclears will have an absolute legal right to see their own files.

I have more than enough documentation to demonstrate that Scientology is in breach of certain of the Data Protection Act's rules, and I will be writing to the Data Protection Registrar shortly. In view of Scientology's previous record in this field, they are certain to be interested.

In the meantime it's important that Scientology's belated registration with the Registrar be tested. It may now have registered to comply - at least partially - with the Act, but it also has to fulfil its other new legal obligations as well. Anyone who has had any dealings whatsoever with Scientology in the UK at any time - whether as a member or not - is legally entitled to see and, if necessary, correct whatever personal data Scientology is holding on them. Scientology is under a legal obligation to respond within 40 days. If you get in touch with me, I'll provide a standard letter which you can send to either of the Scientology organisations which have registered.

I should make clear that the intention in all of this is *not* to harass or tie up Scientology, merely to ensure that it's being a good citizen and following the law. If it does that, fine. If instead it decides that the law of Hubbard comes before the law of the land, it deserves to be clobbered. You wouldn't want <insert anonymous megacorporation> to abuse your personal privacy; why accept that from the Church of Scientology?

The registrations in full are as follows, retrieved from the Data Protection Registrar's website at http://www.dataprotection.gov.uk:

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DPR - K4260404 , CHURCH OF SCIENTOLOGY RELIGIOUS EDUCATION COLLEGE INC The Data Protection Register

Data Protection Act 1984. Register of Data Users and Computer Bureaux Registration Number: K4260404 Registered: 10-DEC-99 , 09-DEC-02 Type of entry: Data User Only Name: CHURCH OF SCIENTOLOGY RELIGIOUS EDUCATION COLLEGE INC Address: SAINT HILL MANOR EAST GRINSTEAD WEST SUSSEX RH19 4JY Addresses for the receipt of requests from data subjects for access to the data: CHURCH OF SCIENTOLOGY SAINT HILL MANOR EAST GRINSTEAD WEST SUSSEX RH19 4JY

This register entry contains personal data held for 7 purpose(s)

This register entry describes, in very general terms, the personal data being processed by: CHURCH OF SCIENTOLOGY RELIGIOUS EDUCATION COLLEGE INC

PURPOSE 1 Purpose for which data are to be held or used: P004 Marketing and Selling (including direct marketing to individuals) Further details of purpose: The identification of potential customers and administration of promotional campaigns including selling or promotion to individuals by direct marketing methods. Typical activites

Typical activities are: the classification, rating or checking of individuals; distribution of promotional materials by mail, door to door delivery or other means; telephone or face to face marketing or canvassing; dealing with complaints or enquiries; analysis for management purposes and statutory returns. Organisation's particular business activities:

ENLIGHTENMENT OF MEMBERS AND SUPPORTERS OF THE CHURCH AND THE GENERAL PUBLIC THROUGH PROMOTION OF BOOKS AND LITERATURE IN RELATION TO THE RELIGIOUS COUNSELLING AND EDUCATION COURSES OF THE CHURCH IN ACCORDANCE WITH THE RELIGIOUS DOCTRINES OF THE CHURCH OF SCIENTOLOGY. Description of personal data (DATA SUBJECT):

S001 Current, past, potential employees, trainees, voluntary workers S004 Current, past, potential recipients, customers or clients for goods or services (direct or indirect) S007 Current, past, potential account holders S016 Current, past, potential members, supporters of a club, society, institution S024 Current, past correspondents and enquirers S040 Current members of the public

Description of personal data (DATA CLASS):

C001 Personal identifiers C011 Personal details C014 Personality,character C021 Current marriage or partnership C023 Details of other family,household members C031 Accommodation or housing C032 Property,possessions C061 Current employment C081 Income, assets, investments C082 Liabilities,outgoings C091 Goods,services provided to the data subject C093 Financial transactions C101 Business activities of the data subject C111 Physical health record C112 Mental health record

Sources and disclosures directly associated with data subjects:

D101 SD The data subjects themselves D CHURCH OF SCIENTOLOGY INTERNATIONAL, LOS ANGELES, CALIFORNIA, U.S.A D CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANISATION, CLEARWATER, FLORIDA,USA D INTERNATIONAL ASSOCIATION OF SCIENTOLOGISTS, C/O SAINT HILL MANOR, EAST GRINSTEAD, SUSSEX D AUTHOR SERVICES INC., LOS ANGELES, CALIFORNIA, U.S.A D RELIGIOUS TECHNOLOGY CENTER, LOS ANGELES, CALIFORNIA, U.S.A D NEW ERA PUBLICATIONS INTERNATIONAL APS, COPENHAGEN, DENMARK

Sources and disclosures directly associated with the data user - Other:

D CHURCH OF SCIENTOLOGY INTERNATIONAL, LOS ANGELES, CALIFORNIA, U.S.A D CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANISATION, CLEARWATER, FLORIDA,USA D INTERNATIONAL ASSOCIATION OF SCIENTOLOGISTS, C/O SAINT HILL MANOR, EAST GRINSTEAD, SUSSEX D AUTHOR SERVICES INC., LOS ANGELES, CALIFORNIA, U.S.A D RELIGIOUS TECHNOLOGY CENTER, LOS ANGELES, CALIFORNIA, U.S.A D NEW ERA PUBLICATIONS INTERNATIONAL APS, COPENHAGEN, DENMARK Overseas transfers - Specified none:

T999 Worldwide T999 INTERNATIONAL RELIGIOUS ORGANISATION

Overseas transfers - Specified worldwide:

T999 INTERNATIONAL RELIGIOUS ORGANISATION

PURPOSE 2 Purpose for which data are to be held or used: P016 Research and Statistical Analysis Further details of purpose: Research or statistical analysis in all fields, including scientific, technical, health, social, economic or market research.. Typical activites

Typical activities are: the identification of subjects for survey or analysis; collection or abstraction of data, including distribution of questionnaires and telephone or face-to-face interviews; analysis, modelling or simulation; evaluation of behaviour, attitudes or characteristics; the output/presentation of results or findings; analysis for management purposes and statutory returns. Purpose:

STATISTICAL ANALYSIS OF ACTIVITIES OF THE CHURCH. Description of personal data (DATA SUBJECT):

Description of personal data (DATA CLASS):

C001 Personal identifiers C011 Personal details C014 Personality,character C021 Current marriage or partnership C061 Current employment C091 Goods,services provided to the data subject C093 Financial transactions

Sources and disclosures directly associated with data subjects:

D101 SD The data subjects themselves D203 D Employees, agents

Sources and disclosures directly associated with data user:

D203 D Employees, agents Overseas transfers - Specified none:

T999 Worldwide T999 INTERNATIONAL RELIGIOUS ORGANISATION

Overseas transfers - Specified worldwide:

T999 INTERNATIONAL RELIGIOUS ORGANISATION

PURPOSE 3 Purpose for which data are to be held or used: P010 Membership Administration Further details of purpose: The administration of membership, other than share/stock-holding registration.

Typical activites

Typical activities are: recruitment; maintenance of professional standards; administration of subscriptions; maintenance of lists of consultants; production of directories or yearbooks; processing of enquiries or complaints; provision of advice or assistance to members; analysis for management purposes and statutory returns. Description of personal data (DATA SUBJECT):

S016 Current, past, potential members, supporters of a club, society, institution

Description of personal data (DATA CLASS):

C001 Personal identifiers C011 Personal details C014 Personality,character C021 Current marriage or partnership C023 Details of other family,household members C036 Lifestyle C040 Complaint, incident, accident details C041 Court, tribunal,inquiry proceedings C057 Student record C091 Goods,services provided to the data subject C093 Financial transactions

Sources and disclosures directly associated with data subjects:

D101 SD The data subjects themselves D203 SD Employees, agents D367 D Lawyers

Sources and disclosures directly associated with data user:

D203 SD Employees, agents Sources and disclosures of organisations or individuals (General description):

D367 D Lawyers Overseas transfers - Specified none:

T999 Worldwide T999 INTERNATIONAL RELIGIOUS ORGANISATION

Overseas transfers - Specified worldwide:

T999 INTERNATIONAL RELIGIOUS ORGANISATION

PURPOSE 4 Purpose for which data are to be held or used: P006 Public Relations and External Affairs Further details of purpose: The promotion of mutual understanding between the data user and representatives of the public, public authorities or other organisations. Typical activites

Typical activities are: the identification of organisations or individuals representations or lobbying on matters of concern to the data user; the maintenance of associated records; analysis for management purposes and statutory returns. Description of personal data (DATA SUBJECT):

S012 Current, past, potential business or other contacts S013 Current, past, potential advisors, consultants, professional and other experts S016 Current, past, potential members, supporters of a club, society, institution S024 Current, past, potential correspondents and enquirers S036 Current, past, potential elected representatives, other holders of public office S037 Current, past, potential authors, publishers, editors, artists, other creators

Description of personal data (DATA CLASS):

C001 Personal identifiers C011 Personal details C014 Personality,character C021 Current marriage or partnership C024 Other social contacts C035 Leisure activities,interests C037 Membership of voluntary,charitable bodies C038 Public offices held C053 Membership of professional bodies C055 Membership of committees C056 Publications C061 Current employment C101 Business activities of the data subject C120 Political opinions C121 Political party membership C122 Support for pressure groups C123 Religious beliefs C132 Uncategorised information

Sources and disclosures directly associated with data subjects:

D101 S The data subjects themselves D203 D Employees, agents D379 S Providers of publicly available information, including public libraries, press and media

Sources and disclosures directly associated with data user:

D203 D Employees, agents Sources and disclosures of organisations or individuals (General description):

D379 S Providers of publicly available information, including public libraries, press and media Overseas transfers - Specified none:

T999 Worldwide T999 INTERNATIONAL RELIGIOUS ORGANISATION

Overseas transfers - Specified worldwide:

T999 INTERNATIONAL RELIGIOUS ORGANISATION

PURPOSE 5 Purpose for which data are to be held or used: P001 Personnel/Employee Administration Further details of purpose: The administration of prospective, current and past employees, including, where applicable, self employed or contract personnel, secondees, temporary staff or voluntary workers. Typical activites

Typical activities are: recruitment; recording of working time; administration and payment of wages, salaries, pensions and other benefits with deductions; employee assessment and training; negotiation or communication with employees; manpower and career planning; compliance with company policy and/or legislation in relation to health, safety and other employment matters; analysis for management purposes and statutory returns. Description of personal data (DATA SUBJECT):

S001 Current, past, potential employees, trainees, voluntary workers S009 Current, past, potential partners, directors, other senior officers S013 Current, past, potential advisors, consultants, professional and other experts S038 Current, past immigrants, foreign nationals

Description of personal data (DATA CLASS):

C001 Personal identifiers C003 Identifiers issued by public bodies C011 Personal details C013 Habits C014 Personality,character C021 Current marriage or partnership C023 Details of other family,household members C024 Other social contacts C031 Accommodation or housing C033 Immigration status C034 Travel,movement details C036 Lifestyle C039 Licences,permits held C051 Academic record C052 Qualifications and skills C054 Professional expertise C057 Student record C061 Current employment C062 Recruitment details C063 Termination details C064 Career history C065 Work record C071 Work assessment details C072 Training record C073 Security details C081 Income, assets, investments C082 Liabilities,outgoings C111 Physical health record C112 Mental health record C115 Sexual life C132 Uncategorised information

Sources and disclosures directly associated with data subjects:

D101 SD The data subjects themselves D203 SD Employees, agents

Sources and disclosures directly associated with data user:

D203 SD Employees, agents Overseas transfers - Specified none:

T999 Worldwide T999 INTERNATIONAL RELIGIOUS ORGANISATION

Overseas transfers - Specified worldwide:

T999 INTERNATIONAL RELIGIOUS ORGANISATION

PURPOSE 6 Purpose for which data are to be held or used: P022 Education and training administration Further details of purpose: The provision of education or training as a primary function or as a business activity. Typical activites

Typical activities are: the registration and monitoring of students; accounting for fees and grants; planning and control of curricula and examinations; commissioning and validating educational materials; calculation and publication of examination results; the provision of references; analysis for management purposes and statutory returns. Description of personal data (DATA SUBJECT):

S004 Current, past recipients, customers or clients for goods or services (direct or indirect) S016 Current, past members, supporters of a club, society, institution S024 Current, past correspondents and enquirers S030 Current, past students

Description of personal data (DATA CLASS):

C001 Personal identifiers C011 Personal details C033 Immigration status C057 Student record C058 Student financial records C091 Goods,services provided to the data subject

Sources and disclosures directly associated with data subjects:

D101 SD The data subjects themselves D203 SD Employees, agents D307 D Home office

Sources and disclosures directly associated with data user:

D203 SD Employees, agents Sources and disclosures of organisations or individuals (General description):

D307 D Home office Overseas transfers - Specified none:

T999 Worldwide T999 INTERNATIONAL RELIGIOUS ORGANISATION

Overseas transfers - Specified worldwide:

T999 INTERNATIONAL RELIGIOUS ORGANISATION

PURPOSE 7 Purpose for which data are to be held or used: P018 Trading in Personal Information Further details of purpose: The sale, hire or exchange of personal information (whether through the data user disclosing personal information or using it on behalf of a third party). Typical activites

Typical activities are: the maintenance and distribution , as a business activity, of information or databanks consisting primarily of data about individuals; the use of such information or databanks on behalf of third parties; analysis for management purposes and statutory returns. Description of personal data (DATA SUBJECT):

Description of personal data (DATA CLASS):

C001 Personal identifiers C091 Goods,services provided to the data subject

Sources and disclosures directly associated with data subjects:

D101 SD The data subjects themselves D203 SD Employees, agents D CHURCH OF SCIENTOLOGY INTERNATIONAL, LOS ANGELES, CALIFORNIA , USA. D CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANISATION CLEARWATER FLORIDA USA. D INTERNATIONAL ASSOCIATION OF SCIENTOLOGISTS 90 SAINT HILL MANOR, EAST GRINSTEAD, WEST SUSSEX D AUTHOR SERVICES INC., LOS ANGELES, CALIFORNIA. D RELIGIOUS TECHNOLOGY CENTER, LOS ANGLELES, CALIFORNIA, USA D NEW ERA PUBLICATIONS INTERNATIONAL APS, COPENHAGEN, DENMARK

Sources and disclosures directly associated with data user:

D203 SD Employees, agents Sources and disclosures directly associated with the data user - Other:

D CHURCH OF SCIENTOLOGY INTERNATIONAL, LOS ANGELES, CALIFORNIA , USA. D CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANISATION CLEARWATER FLORIDA USA. D INTERNATIONAL ASSOCIATION OF SCIENTOLOGISTS 90 SAINT HILL MANOR, EAST GRINSTEAD, WEST SUSSEX D AUTHOR SERVICES INC., LOS ANGELES, CALIFORNIA. D RELIGIOUS TECHNOLOGY CENTER, LOS ANGLELES, CALIFORNIA, USA D NEW ERA PUBLICATIONS INTERNATIONAL APS, COPENHAGEN, DENMARK Overseas transfers - Specified none:

T009 Denmark

Overseas transfers - Specified worldwide (associated text):

T009 Denmark

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DPR - K3414749 , DIANETICS AND SCIENTOLOGY MISSION OF BOURNEMOUTH LTD The Data Protection Register

Data Protection Act 1984. Register of Data Users and Computer Bureaux Registration Number: K3414749 Registered: 24-APR-97 , 23-APR-00 Type of entry: Data User Only Name: DIANETICS AND SCIENTOLOGY MISSION OF BOURNEMOUTH LTD Address: GOLDHANGER 6 PORTLAND ROAD EAST GRINSTEAD WEST SUSSEX RH19 4DZ Addresses for the receipt of requests from data subjects for access to the data: 42 HIGH STREET POOLE DORSET BH15 1BT

DOLPHIN HOUSE 3 MARKET CLOSE POOLE DORSET BH15 1NQ

This register entry contains personal data held for 5 purpose(s)

This register entry describes, in very general terms, the personal data being processed by: DIANETICS AND SCIENTOLOGY MISSION OF BOURNEMOUTH LTD

PURPOSE 1 Purpose for which data are to be held or used: P001 Personnel/Employee Administration Further details of purpose: The administration of prospective, current and past employees, including, where applicable, self employed or contract personnel, secondees, temporary staff or voluntary workers. Typical activites

ADMINISTRATION AND PAYMENT OF WAGES, SALARIES. Description of personal data (DATA SUBJECT):

S001 Current employees, trainees, voluntary workers S009 Current partners, directors, other senior officers

Description of personal data (DATA CLASS):

C001 Personal identifiers C003 Identifiers issued by public bodies C068 Payments,deductions

Sources and disclosures directly associated with data subjects:

D101 SD The data subjects themselves D301 D Inland revenue

Sources and disclosures of organisations or individuals (General description):

D301 D Inland revenue Overseas transfers - Specified none:

T000 None

PURPOSE 2 Purpose for which data are to be held or used: P008 Purchase/Supplier Administration Further details of purpose: The administration of supplies of goods or services to the data user, by whatever method of contract or payment, including subscriptions and standing orders as well as discrete purchases. Typical activites

Typical activities are: the identification, checking and selection of suppliers; ordering; recording and processing of goods received and payments (purchase ledger); monitoring supplier performance; analysis for management purposes and statutory returns. Description of personal data (DATA SUBJECT):

S005 Current, past suppliers of goods or services (direct or indirect)

Description of personal data (DATA CLASS):

C092 Goods,services obtained from the data subject C093 Financial transactions

Sources and disclosures directly associated with data subjects:

D101 SD The data subjects themselves

Overseas transfers - Specified none:

T000 None

PURPOSE 3 Purpose for which data are to be held or used: P013 Customer/Client Administration Further details of purpose: The administration of orders and accounts relating to customers or clients. Typical activites

Typical activities are: recording and processing of orders and payments (sales ledger); credit checking or rating; control and monitoring of after sales service or maintenance; dealing with customer complaints or enquiries; analysis for management purposes and statutory returns. Purpose:

RECORDING AND PROCESSING OF ORDERS AND PAYMENTS. Description of personal data (DATA SUBJECT):

S001 Current, past employees, trainees, voluntary workers S004 Current, past recipients, customers or clients for goods or services (direct or indirect) S007 Current, past account holders

Description of personal data (DATA CLASS):

C091 Goods,services provided to the data subject C093 Financial transactions

Sources and disclosures directly associated with data subjects:

D101 SD The data subjects themselves D105 D Employees, agents

Overseas transfers - Specified none:

T000 None

PURPOSE 4 Purpose for which data are to be held or used: P018 Trading in Personal Information Further details of purpose: The sale, hire or exchange of personal information (whether through the data user disclosing personal information or using it on behalf of a third party). Typical activites

S004 Current, past recipients, customers or clients for goods or services (direct or indirect)

Description of personal data (DATA CLASS):

C001 Personal identifiers C014 Personality,character

Sources and disclosures directly associated with data subjects:

D101 SD The data subjects themselves D106 D Colleagues, business associates D202 D Other companies in the same group

Sources and disclosures directly associated with data user:

D202 D Other companies in the same group Overseas transfers - Specified none:

T000 None

PURPOSE 5 Purpose for which data are to be held or used: P004 Marketing and Selling (including direct marketing to individuals) Further details of purpose: The identification of potential customers and administration of promotional campaigns including selling or promotion to individuals by direct marketing methods. Typical activites

DISTRIBUTION OF PROMOTION MATERIALS BY MAIL, TELEPHONE OR FACE-TO-FACE MARKETING OR CANVASSING. Description of personal data (DATA SUBJECT):

S004 Current, past recipients, customers or clients for goods or services (direct or indirect) S024 Current, past correspondents and enquirers S025 Current survey respondents, other persons assisting research

Description of personal data (DATA CLASS):

C001 Personal identifiers C014 Personality,character

Sources and disclosures directly associated with data subjects:

D101 SD The data subjects themselves D105 SD Employees, agents D202 D Other companies in the same group

Sources and disclosures directly associated with data user:

D202 D Other companies in the same group Overseas transfers - Specified none:

T000 None