Your procedures as described above mirror the advice I was given.
--

I hope they didn't charge you, I would have given the information free :-))

Seriously, you have to sort out EXACTLY what you are doing with the names
and addresses and how you are going to use them.

One man joined my System a few years back, found that there was an
Association for his class of warship, joined that association and was
reunited with 12 of his shipmates from WWII. He 'had' to join that
association to get the names and addresses. To a certain degree, I am only a
'hub' and a guide to show where to go for more information. I had a case of
an American gentleman with an English wife. She was born in November 1942 as
her father was killed in the June of 1942 when a bomb hit his ship in Malta.
I was able to direct her to an Association which covered her father's class
of ship. She came to the UK, met 3 of her father's old shipmates, one of
which was in the same mess and knew him well. She also went to Malta and saw
the dock where the ship was when hit.

I am not clever or the best thing since sliced bread. I have all of this
information because it has been passed on to me IN CONFIDENCE, and that I
will not give names and address away willy nilly. The Ministry of Defence
refer people to me as does the Imperial War Museum and many others. But I am
still not registered with the DPA and don't need to.

Funny old Act :-))

Mike