Back in April 2018 we published an insight piece on the lawful basis for using Facebook’s Custom Audiences tool, in which we concluded that relying on legitimate interests as a lawful basis for the use of this feature was unlikely to be suitable, and that consent was a more appropriate basis. Well, it seemed we …
With the GDPR, a DPIA, or ‘Data Protection Impact Assessment’ has moved from being a good practice recommendation to being a mandatory activity for some kinds of personal data processing. The purpose of a DPIA is to identify potential risks to data subjects’ rights and freedoms before the processing begins, so that appropriate measures can …
This article is not a guide about how to handle a notifiable breach. By now, you’re all familiar with the ICO Guidance on that. This piece is about the day to day handling of incidents based on over a decade of first-hand experience about what works, and what doesn’t. Keep it simple. If the breach/incident …
At the Protecture seminar on e-Privacy at the end of November, Rowenna Fielding reminded us that PECR is about more than just consent for electronic direct marketing. I don’t think that Rowenna meant to alarm anyone, just a gentle poke in the ribs to get your online house in order before the new ePrivacy Regulation …
The Information and Records Management Society (IRMS) and Protecture were delighted to formally launch the IRMS Third Sector Retention and Disposal Toolkit and Schedule at an event in Central London last week. Attendees from a number of charities, not-for-profits and companies heard Scott Sammons, Chair of the IRMS, argued passionately for the benefits of record …
Launch of the IRMS Third Sector Retention and Disposal Toolkit Read More »
As the Data Protection Act 1998 (DPA98) comes to an end, we have a first! The first maximum fine under the old law was issued in September to Equifax Ltd. If you’ve heard any of the Data Protection Leads here at Protecture speak about basic security issues facing organisations, you will have heard us talk …
With the news that the changes to ePrivacy law have now been delayed until 2020, now is a good time to evaluate whether your organisation’s practices are already in line with existing electronic privacy law. The ePrivacy Regulation is likely to strengthen the current provisions of PECR in similar ways to which GDPR strengthened previous …
On the 1st of August a hugely popular website, Reddit, announced that it had been hacked. If you’ve not seen it, Reddit is a vaguely social network (explored further below) where registered members can post links, news and discuss almost anything on a series of message boards. Users need an email address and password but are seemingly anonymous …
The ICO Annual Report for 2016-17 has been published. Among the findings reported is the number of self-reported data protection incidents, broken down by sector. The headline figures show a 31.5% increase in self-reported incidents – from 1,950 to 2,565 incidents. The key word here: self. Reporting of actual or suspected incidents to the ICO …
Better the devil you know – personal data breach reporting and GDPR Read More »
On 27th March 2017, the ICO issued Monetary Penalty Notices to Honda and Flybe, having determined that their approaches to confirming customers’ contact details and marketing preferences were not compliant with PECR (The Privacy & Electronic Communications Regulations 2003). Since these fines were issued, there has been some concern about whether this means that verification …
Updating consent – implications of the Flybe and Honda fines Read More »
