Hi all
I have read with interest the discussions around the new Regs and would like to share my thoughts which may also prompt a discussion.
As an IG Specialist I am comfortable with the Regs and of the opinion that they are practical to implement. My thought process is this; the ICO on rulings he has made have been a practical approach.
If you draw a line in the sand that is that legacy info systems and data structures may not make it practical to apply the Regs in the purest sense but that you have where possible applied; that you have evidence moving forward you are designing (PbD) your systems and data structures to accommodate the compliance of the new Regs then that should be sufficient mitigation for the ICO should you be challenged on applying the new Regs on data and ICT systems retrospectively.
The Regs as they stand in terms of achieving increased protection are sound and in my professional opinion do not cause me a concern as I think they are workable practical to apply without too much added work.
I think along the lines of the myth "can't share cause of DPA", in my years of experience I have never come across a situation where I have not been able to meet a business need either internally or externally to share data. However I have changed what is shared to ensure its lawful but still able to meet all business objectives without invading unduly on one's privacy rights.
This is just my opinion and I appreciate that not everyone on this List may agree but just wanted to share my thoughts.
Sent from my iPhone
Regards
Trish-louise Bailey Msc
Information Governance Specialist
07545 445799
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