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I suspect the ICO is thinking of emergency rectification of systems 
where the business is dead in the water because of a failure, not run of 
the mill "let's test this" scenarios.

Under those circumstances the least worst scenario is to use extreme 
care and test on live data, but a minimum sample.

laura thomas wrote:
>
> For what its worth, the ICO states that live data should not be used 
> except where absolutely unavoidable
>
> Laura
> ------------------------------------------------------------------------
> Date: Thu, 9 Oct 2008 12:53:04 +0100
> From: [log in to unmask]
> Subject: Re: [data-protection] Use of Live data in testing
> To: [log in to unmask]
>
> I don't disagree with the essence of your argument but sometimes the 
> use of live data may be the only option. It then boils down to how you 
> square the DPA circle and also ensure sufficient security controls are 
> in place.
>
>  
>
> System testers are paid to test systems, but they need quality test 
> data to be able to do this, they have to have the tools. I am aware, 
> for example,  of a system development at the moment that really needs 
> the broadness of live data in order to test properly. It is also 
> critical that the quantity of data is the same as live in order to 
> test response times to requests.
>
>  
>
> Yes, you can sort column 1 from A to Z and mess around with columns, 
> and this may work really well for a database of a few thousand 
> records. However the database I refer to has in excess of 70 million 
> records, just spragging (a technical term) the live data will take 
> days. There is then the issue of several columns being dependent on 
> others. Sometimes randomising is not truly an option as depending on 
> the value of column X then column Y has to be a certain range of 
> values which in turn affects column B and if this is randomised the 
> data becomes useless. Yes, you could write something to allow this, 
> but then you are developing a programme to enable you to develop a 
> system, which needs testing, where does it end?
>
>  
>
> Obviously test data will ideally be made up data, but sometimes this 
> is simply not practical and is one area where the DPA and other 
> legislation is woefully inadequate.
>
>  
>
> Question -- A new system is being developed. Testing a new system is a 
> form of research. Therefore couldn't testing be exempted?
>
>  
>
> Simon Howarth.
>
>  
>
> *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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