Worth looking at the ICO’s monetary penalty on the Crown Prosecution
Service from November 2015 for CPS mishandling of a similar situation.
--
Tim Turner
On 8 July 2016 at 11:38:55, Phil Bradshaw ([log in to unmask]) wrote:
Absolutely nothing wrong with this as long as you have a solid data
processing contract compliant with principle 7 ...
AND
have very careful regard to the other requirements of P7 in particular:
"choose a data processor providing sufficient guarantees in respect of the
technical and organisational security measures governing the processing to
be carried out, and take reasonable steps to ensure compliance with those
measures."
Signed confidentiality agreements is clearly not enough. Full due
diligence. Probably need verifiable DBS checks on all who have access.
Ensure contractor staff appropriately trained (including specific awareness
of potential criminal liabilty under s55 DPA and Computer Misuse Act) and
verify all of above by audit would be a minimum.
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