Chris
I vividly recall your (jokey) advice in the early '90s that, when faced with a problematic Data Subject, the solution was to bump them off ... thus putting them outside the ambit of the DPA. :-)
Regards - Michael Bacon
Grimbaldus Limited
> On 30 Jan 2015, at 12:10, "Chris Pounder" <[log in to unmask]> wrote:
>
> Nobody has mentioned that some of the "data subjects" have been killed - might not be a loss at all.
>
> -----Original Message-----
> From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Michael Bacon - Grimbaldus
> Sent: 30 January 2015 11:46
> To: [log in to unmask]
> Subject: Re: [data-protection] BBC news reporting serious data loss
>
> As the ICO has frequently referred in enforcement notices to an inadequacy of training having contributed to a 'non-compliance', one might well consider that a breach of (corporate) policy constitutes failure of an organisational control.
>
> Controls come in two distinct types: preventative and detective. A failure to detect a 'breach' or the circumstances leading to the breach is arguably a failure of a control (most probably through its absence).
>
> The Regulation (even in its currently emasculated form, I believe) counts non-compliances with it as notifiable 'breaches'.
>
> Best - Michael
>
>
> -----Original Message-----
> From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Jonathan Baines
> Sent: 30 January 2015 11:03
> To: [log in to unmask]
> Subject: Re: [data-protection] BBC news reporting serious data loss
>
> But what if the person who did this at the DC acted in contravention of all the controls? (ignoring for the purposes of this discussion an argument - ad absurdum - that if someone is allowed to subvert all controls that is a control failure in itself).
>
> If that happened in what way would the DC have contravened (breached) its section 4(4) obligation to comply with the DPPs?
>
> Jon
>
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