It doesn't matter whether the information is available in a phone book or anywhere else. If you are taking and holding information on a customer, you must be registered.
Don't worry though - you're not gonna end up in prison for a breach - think of the stupid idiots that have lost all that personal data on millions of people stored on lost laptops.
Anyway, this is the ICO's checklist
- Do I really need this information about an individual? Do I know what I'm going to use it for?
- Do the people whose information I hold know that I've got it, and are they likely to understand what it will be used for?
- If I'm asked to pass on personal information, would the people about whom I hold information expect me to do this?
- Am I satisfied the information is being held securely, whether it's on paper or on computer? And what about my website? Is it secure?
- Is access to personal information limited to those with a strict need to know?
- Am I sure the personal information is accurate and up to date?
- Do I delete or destroy personal information as soon as I have no more need for it?
- Have I trained my staff in their duties and responsibilities under the Data Protection Act, and are they putting them into practice?
- Do I need to notify the Information Commissioner and if so is my notification up to date?
I hope this helps.
Don't worry if you have to register, as it's fairly easy. The only painful bit is paying for it, but £35 shouldn't break the bank