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Interestingly I just un-installed Rapport yesterday from my wife's home office PC.  But for the rather non-privacy issue (so excuse me for cross posting) that it stopped my wife from working.  She is an architect and Rapport causes AutoCad not to work. Trusteer say its a bug in her (early version of) AutoCAD and she should spend £1000 to get a newer version which doesn't have a bug! (Bug or no bug, it used to work - so uninstall we did).
 
If they do analyse in the cloud and try to identify patterns, I image that at the very least they are doing something with IP addresses. 
 
Now, they might be taking the view that ip addresses do not sufficiently identify an individual (rather than computers or a range of computers or a range of individuals) so that data protection law does not apply.   But still, you would have thought they would make it clearer. 
 

Renzo Marchini
Dechert LLP
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________________________________

	From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Baines, Jonathan
	Sent: 01 February 2010 10:12
	To: [log in to unmask]
	Subject: Re: [data-protection] Banks and extra security layers
	
	
	Tim - I think this is the same message my girlfriend got from her bank.
	 
	What concerns me is the phrase you highlight: they "would like you to use" the software. As far as I can see this is your bank marketing a piece of software which they support (and for which they no doubt receive some consideration). The implication to those unused to this sort of thing will be that, in order to bank with this firm, you NEED to install the software. As many of us will be very aware, with the installation of any anti-malware program there is a risk of conflicts with other software, incompatibility with older browser versions etc.
	 
	Various discussions about this out on t'interwebs, e.g. http://www.computing.net/answers/security/rapport-installed-problems/24888.html <http://www.computing.net/answers/security/rapport-installed-problems/24888.html>  

	best wishes

	Jonathan

	Jonathan Baines 
	Complaints Officer 
	Legal and Democratic Services 
	Buckinghamshire County Council 
	tel: 01296 383681 
	fax: 01296 382421 


________________________________

	From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Tim Trent
	Sent: 01 February 2010 00:09
	To: [log in to unmask]
	Subject: [data-protection] Banks and extra security layers
	
	
	My bank is doing a lousy job at selling me an extra layer of security it "would like me to use" for internet banking. They have failed to explain what they mean and what the new service does.  It is Trusteer's Rapport service which is a browser plugin. 

	Apart from wondering about other plugins that might masquerade as this one I have found the following paragraph on the Trusteer product description:

	"Unauthorized attempts to access the browser or its communication are automatically reported to the Trusteer cloud-based fraud analysis service. The Trusteer team of fraud analysts works 24x7 analyzing this information from customers all over the world, in order to identify new attack patterns. Institutions registered for the Trusteer service receive immediate reports and actionable alerts of new attacks, and can learn of attacks as they happen, instead of days, weeks, and sometimes months later."
	
	
	Nowhere does it state whether personal information is transmitted.  I doubt that it is, but would be interested in knowledge that members may have of this and similar services.  My first instinct is always to be sceptical of services that an institution wishes me to install.
	
	
	Also, when you ask your users to deploy something, how well do you sell the idea to them? And do you recognise that some methods of doing this raise user hackles instead of acting as a salve to the users?
	
	
________________________________


	Tim Trent - Consultant
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