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Quantity of information put at risk? If your paper is 50 lines of 72 characters then a single 1.4MB floppy is about 400 sheets of (single-sided) paper.

The amount of paper represented by the original HMRC loss of 27M records doesn't bear thinking about - possibly why they didn't have a policy on "don't put it in the post" :(

Andrew


> -----Original Message-----
> From: This list is for those interested in Data Protection issues
> [mailto:[log in to unmask]] On Behalf Of Lawrence Serewicz
> Sent: 16 June 2011 13:19
> To: [log in to unmask]
> Subject: Re: HMRC and personal data
> 
> Jane,
> Good question. My first guess is that paper cannot be encrypted but a
> disk can.  If you fail to encrypt the disk, even though you know the
> need, then you can be seen not to have taken reasonable steps.
> 
> If there was a way to encrypt paper, as paper, then that would need to
> be considered.  Ideally, if the information is sensitive personal (as
> opposed to personal information) I would expect a courier service to
> demonstrate the reasonable steps to keep information secure.
> 
> So far as I can see, the breaches and the fines have been around
> sensitive personal information rather than just personal information.
> 
> Happy to be corrected.
> 
> Best,
> 
> Lawrence
> 
> 
> 
> -----Original Message-----
> From: This list is for those interested in Data Protection issues
> [mailto:[log in to unmask]] On Behalf Of Jane Holden
> Sent: 16 June 2011 13:02
> To: [log in to unmask]
> Subject: Re: [data-protection] HMRC and personal data
> 
> This is probably a really stupid question so forgive me but I'm at a
> loss to see what the difference is between sending personal data in
> paper format via post and an unencrypted disc?
> 
> 
> Jane Holden
> Corporate Services Officer
> Legal Services
> Barrow-in-Furness Borough Council
> Town Hall, Duke Street
> Barrow-in-Furness
> Cumbria  LA14 2LD
> Tel:  01229 876452
> Fax: 01229 876515
> 
> 
> 
> 
> 
> -----Original Message-----
> From: This list is for those interested in Data Protection issues
> [mailto:[log in to unmask]] On Behalf Of Bailey, Trish
> Sent: 16 June 2011 12:56
> To: [log in to unmask]
> Subject: Re: [data-protection] HMRC and personal data
> 
> Phil
> 
> Your obligation is to the organisation you are working for as in the
> "eyes" of the law your org is the Data Controller and responsible for
> the transfer.  I would personally (as far as possible) insist on a form
> of encryption for the transfer of data or alternatively (send it via
> Gov Connect - which would not require the encryption of the actual
> information.
> 
> I would also be inclined to speak to ICO and explain your situation and
> ask what they can advise.  Either way an acceptable method of transfer
> needs to be reached (its not that you are not cooperating but your
> organisation has obligations under DPA as well as everyone else).
> 
> I absolutely astonished that HRMC are operating in this manner - it
> would appear lessons have not be learned.
> 
> Many thanks
> Trish
> Trish-louise Bailey
> Audit & Assurance (Information Governance)
> (IG covers:  Data Protection & Privacy, FOI, Information Security,
> Information Sharing & Confidentiality, Information & Records
> Management, Information Quality & Assurance)
> Telford & Wrekin Council
> Civic Offices
> Coach Central
> Telford
> TF3 4HD
> www.telford.gov.uk
> 
> em:   [log in to unmask] or [log in to unmask]
> tel:    01952 382537
> mb:   07528 969455
> 
> -----Original Message-----
> From: This list is for those interested in Data Protection issues
> [mailto:[log in to unmask]] On Behalf Of Phil Bradshaw
> Sent: 15 June 2011 17:24
> To: [log in to unmask]
> Subject: HMRC and personal data
> 
> I have been consulted by my payroll team.
> 
> I am told that HMRC require us to export P11d information (which from a
> tax perspective is about mileage claims and includes staff personal
> data), and this gets placed on floppy disk (cd's not allowed !)  and
> sent "via post" to HMRC. As far as can be discerned there is no
> encryption being used. The HMRC website says that the files must not be
> "compressed" - whatever that means - and why, since there should never
> be any issues with lossless compression or encryption as the "original"
> file can be duplicated.
> 
> Has anyone come across this. I am amazed, in view of history, that HMRC
> sanction this. I am still trying to get chapter & verse from HMRC but
> they are rather unresponsive at the moment. I can of course use a
> traceable courier service if it would place us in breach of our tax
> obligations to delay the info. , but even that places me in breach of
> our own policy which is now quite clear : "where possible avoid the use
> of removable media for the storage or transfer of personal data and
> where this is not possible use an appropriate level of encryption ".
> 
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