FOI Request - Register of Licensed Premises
I am writing in connection with an authorised list of all license holders within Moray approved by local authority.
I am searching for a source of valid licence holders name and most of all their email address.
Details of licensed premises with licence holder name can be found here. We have taken the content of the request to mean liquor licensed premises. Unfortunately email addresses do not form part of the public register for licensed premises.
- We can release information in accordance with the Licensing Register (Scotland) Regulations 2007 without any further examination. However, that does not include email addresses.
- We do not necessarily collect or hold email addresses for all licence holders.
- Further, in respect of email addresses we do hold, it is not the Council's practice to give out email addresses to third parties and so when email addresses are collected no fair processing/privacy notice has been given in this respect.
- The only information within the request about how the information will be used is that it is intended to give notice to all licence holders about the SLTN. The ICO makes it clear that it is not acceptable to seek to justify disclosing customer information without consent to another organisation for marketing on the grounds that it is in the interests of customers to receive useful offers.
- Therefore individual consent would be required for this purpose and individuals would have to make an informed decision