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Surely it all comes down to the PURPOSE for which you declared you would use the data when registering under the act.  There is nothing that needs to be read here, is there?

Did you declare that the data would be used for TESTING?  if so then you can do it.  If not then you can not.

The excuse so often given is that "live data tests the parts of the system that test data cannot test."

No it doesn't.  The people testing the system are responsible for testing the system, and their job is to test the entire system.  If you don;t test that part then live or test data is irrelevant.

It is very easy to randomise fields across what was live data in order to render it 100% anonymous, too.  Stick it in a spreadsheet, and sort the forename column a to z, the last name column z to a and then mess about with any other column.  Then load that into the test system and enjoy it.  It does not identify any living individual because it just cannot.

--

Tim Trent - Consultant
Tel: +44 (0)7710 126618
web: ComplianceAndPrivacy.com - where busy executives go to find the news first
personal blog: timtrent.blogspot.com/

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