Ah the devil is in the detail. But this is still not hard. If they are big
enough for distributed systems in Scunthorpe and Nether Snodsbury then they
are big enough for a database manager.
When I ran a very small telemarketing company we had a database manager who
did this stuff for multiple clients for multiple campaigns as well as doing
the rest of this job.
I'll let you defend the workload to an extent, but the major part of this
(15 minutes) is writing the queries. As for the rest, you apply the PC to
them and they run. :)
No, the UKIC is being unduly lenient. Now, Officer, which of these pedals
is the brake?
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Griffiths, Ian
Sent: 12 October 2006 13:46
To: [log in to unmask]
Subject: Re: [data-protection] UKIC and requiring timely compliance with
PECR
Devils advocations inline.
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Tim Trent
Sent: 12 October 2006 13:34
To: [log in to unmask]
Subject: Re: [data-protection] UKIC and requiring timely compliance with
PECR
Get TPS data.
- How long for TPS to respond if BBK don't already have this?
Run query against existing data and delete ALL that match TPS
- Is all data in one place? Do different teams of staff have different
lists? Do TPS numbers match BBK numbers, ie. 0151-123-4567 is not the same
as (0151) 123 4567 is not the same as 01511234567. Is it valid to delete
all data? What if numbers also belong to people who are actually customers?
What if new records are inserted, what is the procedure (which after
December needs to be right) for ensuring future compliance on the inserts?
Probably some other things which would slow you down.
Hmm, that is done, then. Even on a PC we are looking at a maximum of a
couple of hours to run this against a massive database.
- Quite, but thats assuming we have two simple lists available to that PC
and nothing else to do.
Then with new data take on:
Run query to remove TPS data from New data Upload new data
- Assuming new data comes in as large files and the batch process is robust
enough to fix it all. Is this the case? Assuming also that something is in
place to ensure all new data undergoes this check. Are inserts currently
conducted centrally?
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Griffiths, Ian
Sent: 12 October 2006 13:24
To: [log in to unmask]
Subject: Re: [data-protection] UKIC and requiring timely compliance with
PECR
I agree that the time period does seem quite long.
I suspect that although the process of checking data against TPS records is
simple from our perspective, in the context of a large business with a lot
of data this is more difficult. I'm not disagreeing with you, I just think
we don't know enough about their business to comment on their ability to
respond.
However as you also correctly point out, this is not a nice relaxing
transition in to new processes, this is law now and therefore compliance is
already overdue. I have some friends in IT who are working very long and
hard to ensure that they comply with new VISA regulations for security of
their data processing, because if they don't they will be fined money for
each transaction which they process outside of the VISA regs.
The UKIC stance does not quite have the same teeth.
Ian
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Tim Trent
Sent: 12 October 2006 12:47
To: [log in to unmask]
Subject: [data-protection] UKIC and requiring timely compliance with PECR
I'm throwing this open for thoughts. I have a TPS listed domestic number,
and it still gets called by those who, for one reason or another, do not
obey the Privacy and Electronic Communications Regulations. Maybe it's
accidental, maybe it's wilful, who can say?
One such is a kitchen design firm, Bracken Bay Kitchens (BBK). Why is it
always phones or home improvements? Ah well.
The man form the UKIC states that the UKIC has received "a number of
complaints about this company and have investigated these." I like that a
lot. He goes on to say "They have admitted that in recent months they have
had problems in meeting the obligations which PECR imposes on them.
However they have told us that they are now taking steps to ensure their
compliance with these regulations."
Well ok, I can empathise with that, in part. But it doesn't take much to
get the TPS data, scrub their own data against it, and therefore not break
the regulations any more. All it takes is a little knowledge, and it can
even be done in M$oft Access in a very few minutes. So my empathy runs dry
quite fast.
That was the history. The bit I find odd, knowing the simplicity of
handling TPS data, is the following from the UKIC: "As the Information
Commissioner's powers are not punitive (we cannot levy fines or close down
organisations) but are instead focused on ensuring compliance with the law,
we have decided at this stage not to take formal Enforcement action. However
if the Telephone Preference Service and ourselves still continue to receive
complaints about this firm then we will review our position. As Bracken Bay
Kitchens have informed us that their remedial measures will take effect
within the next few weeks we expect to see a marked improvement by early
December."
Well, they could enforce, but if BBK is moving to compliance I see why they
are not doing so. But what I do find to be odd is the huge grace time they
are giving. I see this as a "complete by the end of next week at the
latest" thing. Am I being unrealistic? After all, this is a law, or in
this case a statutory instrument, that is not being complied with.
"Sorry, Officer, I was having a bit of trouble meeting my speed limit
obligations. I WILL get down to below the speed limit soon. Give me a
couple of hours and I'll find the brake!" Or am I just trying to get off a
speeding ticket?
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