Phil
You will need to balance very carefully weigh up the pros and cons. Bearing in mind such things as this:-
--Loss of Unencrypted USB Drive Constitutes Violation of Data
Protection Act, Says ICO
(June 4, 2010)
The UK Information Commissioner's Office (ICO) has found a Welsh medical
practice to be in violation of the Data Protection Act. A staff member
at Lampeter Medical Practice downloaded unencrypted patient data to a
USB drive; the device was then sent to the Health Boards Business
Service Centre by post in March 2010, but the package never arrived.
Downloading unencrypted data onto a removable storage device violates
the practice's data security policy. The head of the practice has
agreed to implement safeguards to ensure that a similar incident will
not happen again. All mobile devices, including laptops, will be
encrypted and staff members will be re-educated about the data security
policy. The breach affected 8,000 patients.
http://www.scmagazineuk.com/welsh-medical-practice-hit-by-ico-after-losing-unencrypted-memory-stick/article/171692/
If no viable working alternative and you can demonstrate that the impact on service is such that it is unacceptable level of risk to the public receiving it and therefore, go down your route of thinking, ensure every step is documented clearly, accurately and as much detail as possible and runs alongside a detailed risk assessment which is constantly monitored.
In addition, you will also need to introduce extra security measures around the handling of these devices and it is made clear that under no circumstances, given the vulnerability of these devices (and the sensitivity of the info), that any violation of council procedures will not be tolerated and penalities severe (which they should be running these devices is a high risk to your council but if no working alternative is available today, then a necessary evil (for service continuity) which must be managed with an "iron fist" so to speak).
I would keep searching for a more viable alternative, the above is in case there is not one after an exhaustive search mind!
Hope this helps
Many thanks
Trish
Trish-louise Bailey
i-Governance (Information Goverance)
(Data Protection & Privacy, Freedom of Information, Information Security, Information Sharing & Confidentiality, Information Assurance, Records & Information Management)
Telford & Wrekin Council
Civic Offices
Coach Central
Telford
TF3 4HD
www.telford.gov.uk
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-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Phil Bradshaw
Sent: 09 June 2010 17:58
To: [log in to unmask]
Subject: Portable Scanning
A growing number of our fieldworkers are using portable scanning to increase efficiency and effectiveness. e.g. they may scan personal documents at a clients home to avoid an office appointemnt or use of post, which causes delay and /or has other risks.
They are typically using pen type devices, which work well in practice. Image is then transferred to a (very secure !) laptop before later upload to main systems.
The scanning devices are however not encrypted. We have not been able to identify workable encrypted alternatives at the present time - too slow, too prone to crash or simply unreliable. They are wiped after transfer before leaving the scanning location. There is a theoretical risk however that if lost, although apprently empty, with the right tools an expert could retrieve most recent images.
Has anyone come across this issue and found a risk free solution ? Or does anyone accept such a risk on the basis that e.g. safer to lose an apparently blank device with a few fairly low level personal documents rather than a briefcase full of originals / photocopies.
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