Can I extend the discussion on pseudonymisation.
There are now many on-line applications that store data in 'the cloud' -
somewhere on the internet but without being too specific. I'm currently
working on a project for a number of voluntary agencies where such a product
is an option under consideration.
However, these agencies exchange personal data with government agencies and
have been told that the data must not leave the UK.
The solution proposed by one supplier is to send the raw data initially to a
location in the UK where it would be pseudonymised before being sent on to
the service provider in the cloud, where it would be stored and processed as
normal. When required, the data would be sent back to the UK, reunited with
its identifying information, and passed back to the user.
Is this a viable mechanism (a) to meet the government requirement, and (b)
to comply with Data Protection requirements? What questions should we be
asking of the supplier?
There do not seem to be any current examples of where this approach is in
use by an official or quasi-official body, but the suppliers claim that it
is sound.
Paul Ticher
0116 273 8191
22 Stoughton Drive North, Leicester LE5 5UB
----- Original Message -----
From: "Marchini, Renzo" <[log in to unmask]>
To: <[log in to unmask]>
Sent: Friday, July 24, 2009 8:30 AM
Subject: Re: Spinvox
Tim
You are right that the incorrect register entry is fairly trivial
(albeit the only criminal offence possibly committed!). Assuming there
is personal data being transferred, they still then need to be a
legitimisation for the transfer, and perhaps there are model contracts
in place (again, fairly trivial to correct, if not yet done).
Then there is the first principle issue of legitimising the processing
by human (irrespective of where the processing takes place). There is
arguably no consent to that (given its hidden), but perhaps its
necessary for performance of the contract (computers being not very good
at this sort of thing). So with a proper privacy notice, that too can
be cured.
Yes, a little storm in a teacup.
I for one, however, am interested in views as to whether the technique
of pseudonymisation used here (which will have wider and more serious
uses) is sufficient to disapply the DPA ... anyone?
Renzo.
________________________________
From: This list is for those interested in Data Protection
issues [mailto:[log in to unmask]] On Behalf Of Tim Trent
Sent: 23 July 2009 23:35
To: [log in to unmask]
Subject: Re: [data-protection] Spinvox
I think I may be alone in seeing a load of fuss about nothing.
All they got wrong was a naive notification, wasn't it? Let's all apply
for the job of Privacy Officer there - it looks like there may be a
vacancy soon!
If you want a giggle at "Tim's Rant" do visit my blog at
http://bit.ly/zR15j where you can giggle all you want.
Or is there more to this that I really can't see (it being a
silly time of day)? Have I made a real chump of myself for once
(once?)?
--
________________________________
Tim Trent - Consultant
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web: ComplianceAndPrivacy.com - where busy executives go to find
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