I was a computer systems analyst for many years and had to test new systems
and investigate faults on 'live' systems. I had to deal with this under
the original 1984 Act as well as the current legislation. The use of 'live'
data for such tests was always acknowledged as being contentious under the
DPA, but pragmatism kicked in when there was a need to correct critical
'live' systems as soon as possible. Contract project managers in particular
had little time for DPA when faced with this situation. Getting the system
back online as soon as possible was the priority. Data was always deleted
after the fault had been corrected.
It is true that it can be difficult and time consuming to prepare test data
that tests all possible situations in a system containing hundreds of
interlinked programs, so 'live' data does overcome that difficulty. The
'live' system will have been tested by IT and users before going 'live', so
clearly errors that occur during 'live' operation have found their way past
the existing test data.
The real difficulty of using 'live' data is that data will be changed during
system testing, so is no longer accurate. System testers will not have
access to new data received by the user department, so the test data may not
be up-to-date either. It is essential that any print-outs produced during
system testing are clearly marked as being test data. Security is another
issue. Some IT professionals involved in the testing would not normally
have access to 'live' data, so there is at least a theoretical increase in
the risk of data falling into the wrong hands. Clearly obtaining the consent
of the data subject would be irrelevant, as the principles of the DPA would
not be adhered to during testing.
In my opinion it is another case of the DPA needing to recognise the 'real'
world, and the difficulties of changing European legislation.
Hope this is of use.
Peter Mead
Email: [log in to unmask]
80 Cadmore Lane
Cheshunt
WALTHAM CROSS
Herts
EN8 9JX
Tel: 01992 635276
Mobile: 07974 425077
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Tim Trent
Sent: 08 October 2008 18:39
To: [log in to unmask]
Subject: Re: [data-protection] Use of Live data in testing
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.
--
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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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