GDPR In The UK

Ed Elliott covers that lesser-known Sex Pistols track in a multi-part series.

Part 1 covers some of the official documentation around how the ICO interprets GDPR:

To read the article, and the actual requirements I would start at page 32 which begins “HAVE ADOPTED THIS REGULATION:” this lists each of the articles (requirements). You can go through each of these and make sure you are compliant with them.

The exciting bit, the fines

The exciting headline-grabbing parts of GDPR are the fines that can be enforced. We don’t yet know how the ICO will apply the fines, words like maximum are used and the maximum possible fines are large. It is possible that the maximum fines will apply but we will look in part 2 at previous ICO enforcement actions to see if the ICO’s past performance gives us any clues as to its possible future decisions.

Part 2 looks at a couple of prior cases and how the ICO handled them:

Talk Talk started mitigating the issue by writing to all of its customers telling them how to deal with scam calls. Talk Talk told the ICO what happened and they responded with their own investigation and a £100,000 fine. The reasons were:

– The system failed to have adequate controls over who could access which records, i.e. anyone could access any record not just the cases they were working on
– The exports allowed all fields, not just the ones required for the regulatory reports
– Wipro were able to make wildcard searches
– The issue was a long-running thing from 2004 when Wipro were given access until 2014

One of the mitigating factors was that there was no evidence that this was even the source of the scam calls, plus there is no evidence anyone suffered any damage or distress as a result of this incident.

Part 3 looks at a couple more cases, too.  And Ed promises part 4.

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