Group,
last December The Information Commissioner met with the Fraud Advisory Panel (FAP) and during the conversation expressed the view that his office regarded investigators (our descriptive term for all non law enforcement investigators) as Data Controllers not Data Processors. FAP were invited to submit their point of view. A draft discussion document has been prepared.
Now at first glance you might not immediately see the relevance to your organisation. But consider all the outsourcing of your processes. A public authority is likely to engage the services of Certificated Bailiffs, Security Personnel, Debt Collection Companies, Forensic Accountants, etc. Are they Controllers or Processors? It is suggested that they would fall into the same category as Investigators.
The object of this paper is to stimulate discussion with the findings eventually being passed onto the Information Commissioner together with another project that FAP is involved in. The Impact of The Privacy Laws on the Investigation and Prosecution of Fraud.
If you would like a copy of this draft document please e mail me privately but by all means discuss it on this site. Your comments would be more than welcome.
This is the second posting of this topic. Sally Justice suggested that it might be worth a second airing. As I have no problem with female authority here it is. Do feel free to use the document as you see fit but please acknowledge those who have helped write it which is quite clear from the document.
Chris Brogan
www.securitysi.com
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