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Given that most P1 breaches are down to individuals the emphasis on P7 is not really surprising. At the organisational level P7 is much more serious. If I send an email enclosure to the wrong person, my authority is vicariously liable for my P1 breach, but far more serious is that it allowed me to do it in the first place - P7.
 
If you look at the penalty notices based on p7 it is clear that they encompass the p1 breaches en passant

From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Lawrence Serewicz
Sent: 27 September 2011 11:48
To: [log in to unmask]
Subject: [data-protection] The ICO does enforce more than the 7th Principle. :) (Eastleigh Undertaking on use of PVP list

Dear All,

I recall there was some discussion as to enforcement action by the ICO beyond the seventh principle.  I thought it would be of interest to note that that the undertaking for Eastleigh  was based on the 3rd and the 7th Data Protection Principles.


20 September 2011

An undertaking to comply with the third and seventh data protection principles has been signed by Eastleigh Borough Council. This follows the potential disclosure of a document containing sensitive personal data.
View the Eastleigh Borough Council undertaking

 

I think it only a matter of time, and resources, before enforcement is recorded against all the principles. I would imagine, given the powers to fine, that the enforcement of principles will follow an arc similar to those for exemptions, decision notices,  and tribunal cases.

 

I hope this is of interest and use.

 

Best,

 

Lawrence

 

Principal Information Management Officer

Durham County Council

Room 4/140

County Hall

County Durham

DH1 5UF

 

0191 372 8371

VPN 77778371

 

 



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