Or even worse
"The view is sometimes expressed that system testing poses no real data protection problem, as it takes place all the time with little apparent detriment
to individuals. The following case study, which is based on a true complaint received by the Information Commissioner's Office, shows that the use of 'live' data to test systems can indeed cause very real problems for individuals. A pupil was away from home at boarding school. The pupil's parents received a letter from the local hospital informing them that their daughter had been involved in a road accident. In fact, there had been no accident, but the hospital had been using live patient data to test a system for sending out letters to patients."
via http://blog.securityactive.co.uk/2010/02/05/information-commissioners-view-on-using-personal-data-for-system-testing/
See also ICO's comments there.
Jonathan Baines
Legal and Democratic Services
Buckinghamshire County Council
01296 383681
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Peter Dinsdale
Sent: Thursday 28 June 2012 14:51
To: [log in to unmask]
Subject: Re: [data-protection] Use of Live (personal) data used within training database
Not exactly the same point, but another demonstration of the dangers of using live data in training environments: http://www.ico.gov.uk/what_we_cover/taking_action/~/media/documents/library/Data_Protection/Notices/durham_university_undertaking.ashx
Peter Dinsdale
Information Security Officer (Compliance)
Tel: 0191 222 6950
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Simon Howarth
Sent: Thursday 28 June 2012 14:39
To: [log in to unmask]
Subject: Re: [data-protection] Use of Live (personal) data used within training database
Just don't do it.
Whilst there are cases when the use of a copy of live data is a requirement in order to test a system - rare, but they do exist, I can see no justification for using live personal information for training. In my opinion that's a folly.
In testing there are things you can put in place. A big system that I had some IG involvement in contained in excess of 60 million individuals'
records. In order to ensure that no cross fertilisation of data could occur and that the data could not get "out", it was put in a secure server dedicated to the test with no external access to the outside world. Further, the testers and developers were put in a room that was secure and the printer they had access to was loaded with pink paper, so that any output could be easily identified. It sounds overkill, but the nature of the system demanded it. I spoke at length with the ICO about this and submitted a plan to use the data and justifying its use.
Training. NO. Never. Ever. 15,000 is not a large database in the big scheme of things so I suggest that data be generated for testing. You may think that all is well for a while, but it only needs one person to make another copy of the database and use it externally for it all to go wrong.
I remember a company several years ago where this happened. A sales guy copied a database and used the information in a presentation to potential customers. Sod's law came into play and the information that sprang up was that of a person in the audience. Can't remember the finer details....
Simon.
Simon Howarth MBCS CITP
www.informationedge.co.uk
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Mike Gater
Sent: 28 June 2012 14:22
To: [log in to unmask]
Subject: [data-protection] Use of Live (personal) data used within training database
Dear all,
Our organisation is about to migrate multiple HR systems (Payroll, People data, leave / sickness absence and security screening data) into one "single" system. ~15,000 employee details.
A copy database has been created for future tech support (testing
environment) and it has been proposed that a further copy is created and subsequently used for system administrator training. The issue I have is that both of these instances will have "Live" data (at the time of
migration) but will not be maintained. As you can imagine some of this data will be rather sensitive, but I take comfort that the trainee would only have access to see the same data that they would see within the Production system. That said, if an individual was to move around within the organisation, it is possible the administrator will still be able to see data about that individual (albeit old data), when in production they would no longer have the access/privilege to do so.
As you can see, for every comfort or justification, I find a worry or issue..... Am I over cooking this, or are there more serious implications than I have thought of (I have not listed all my concerns above)? Has anyone had any experience of this scenario?
Any advice / comments would be greatly received.
Kind Regards
Mike
Records & Information Management
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