This article was all over the place, and in my view complete rubbish. In
some circumstances it is *vital* to use real data to test systems. In a few
cases it would be manifestly irresponsible in my view not to do so.
Obviously the data should be anonymized as far as possible, but - depending
on what is being tested - it may not be possible to anonymize it fully or at
all without invalidating the test.
In the old days, system testing was one of the standard purposes which could
have been declared.
If you look at the compliance audit checklists on the OIC's website, you
will find the question, "Do you permit live data to be used for testing
purposes?" Then, "If so, what procedures are used to protect the personal
data during and after testing?" This implies that it *is* permissible. There
obviously have to be appropriate controls in place, just as with any other
variety of processing.
Regards to all
Tim
--
Tim Wright MA CISA
Director - Technology Audit
Charles Schwab Europe
_______________________________________
WARNING: All e-mail sent to or from this address will be received by
the Charles Schwab Corporate E-mail system and is subject to archival and
review by someone other than the addressee.
Charles Schwab Europe.
Cannon House, 24 Priory Queensway, Birmingham B4 6BS, United Kingdom.
Charles Schwab Europe is a member firm of the London Stock Exchange and LIFFE and
regulated by The Financial Services Authority
Registered Office: As Above. Registered in England No. 2092410 VAT Registration No. GB 486 894471
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
All archives of messages are stored permanently and are
available to the world wide web community at large at
http://www.jiscmail.ac.uk/lists/data-protection.html
If you wish to leave this list please send the command
leave data-protection to [log in to unmask]
All user commands can be found at : -
www.jiscmail.ac.uk/user-manual/summary-user-commands.htm
(all commands go to [log in to unmask] not the list please)
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
|