The Act does not specifically say that real data must not be used
as test data. However, the use of live data as test data has to
be in accordance with the Act (it still remains personal data)
and therefore has to meet all the principles and be properly
justified in relation to a Schedule 2 condition (and a schedule 3
for sensitive data).
Do you tell data subjects that their live data will be used to
test systems and therefore may be accessible to trainees,
external company engineers, etc.? That it will be accessible to
people who would otherwise have no reason to access their
personal data?
Would you be happy if your own data was used as test data and, as
a result, some was amended? Someone then reads the amended test
data and forms an opinion of you based on that incorrect
amendment - they assume that it is still correct live data.
It is still personal data even though in the test environment. It
should therefore be accurate and up to date, but it has now been
erroneously amended and is therefore in breach of the Act.
Therefore, although the Act does not spell out that you cannot
use live data for testing you would be a brave person for doing
so.
John
John F Hitches
General Administrative Manager
Kingston University
River House
53 / 57 High Street
Kingston Upon Thames
Surrey KT1 1LQ
Telephone 020 8547 7768
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