Needs to be consistent to promote transparency (not really demo'ing this by what appears to be a two tier system and for benefit exactly?) and fair (not create a them and us perception). Definitely should be in line with the FSA proposals and .
That's my opinion.
Many thanks
Trish
Trish-louise Bailey (MSc)
Information Governance (IG)
(responsible for: Information Sharing & Confidentiality, Informtaion Security, Information Quality & Assurance, Data Protection, Freedom of Information, Records & Information Management)
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Chris Spray
Sent: 12 November 2009 22:47
To: [log in to unmask]
Subject: Civil Penalty maximum £500k
I'm interested to know contributors views of the MOJ proposal of the Commissioners maximum penalty being £500k? Is this high enough? From the perspective of someone in financial services this doesn't present a level playing field when the Financial Services Authority are fining firms £1m+ for Security ("systems and Controls") breaches with promises to keep increasing the fines.
Chris
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