Freelances and the DPA

The latest NUJ Active email (a regular containing news snippets and reminders for various union things) exhorts members to register as a "data controller" under the Data Protection Act - apparently freelances are required to do so and not registering is a criminal offence (on the basis that we have contact books full of people's phone numbers, email addresses and physical addresses). The NUJ handily includes the link to the Information Commissioner's Office to find out more info. Which would be fine if looking for said info was a tad easier than hunting for the proverbial needle in a haystack.

I spent 20 minutes struggling to find where I might learn more on whether I need to cough up £35 a year or not to be a data controller (can you guess I'm not one?). I looked in all the obvious places, including the FAQs (useless) and the site map, where I used R for register and H for how to... , to no avail. Eventually, more by chance than design, I stumbled across a Notification page. Riiiiiight! How remiss of me not to intuit that I should have been looking under N instead of R for register.

Anyway, I'm still none the wiser. The NUJ says I must, yet over on a journalism forum I use, others say no. One freelance colleague mused on whether his milkman should be registered as a data controller by dint of the fact he keeps his customers names and addresses and how much they owe in a notebook he takes on his rounds. Another said she'd actually called the ICO some months back to enquire if she had to comply and was told that as an individual, she didn't need to be on the register.

So, is the NUJ right? Or do we freelances not need to bother? I'd really like to know what others are doing and if anyone has any kind of solid guidance on this issue.