Data Protection Avoiding Information Commissioner Fines. Caroline Egan 5 June 2014
|
|
- Grant Ross
- 8 years ago
- Views:
Transcription
1 Data Protection Avoiding Information Commissioner Fines Caroline Egan 5 June 2014
2 Why is data protection a hot topic in pensions? Pension schemes hold large amounts of personal data Individuals more aware of their rights Increased powers of Information Commissioner's Office ("ICO") Monetary penalties for serious breaches of Data Protection Act 1998 (the "Act") Up to 500,000 per data protection principle breached Changing guidance on data controllers Comments from the Pensions Regulator Tougher EU legislation on the way 2
3 UK Data Protection Regime: Key Concepts Core principles in the Act The Act controls the way in which personal data of data subjects is used by data controllers or is processed on their behalf by data processors It will cover all information about scheme members held electronically and some paper records Main sanctions for serious breaches: 'Name & shame' Undertakings Enforcement Notices Monetary penalties 3
4 What is Personal Data? Personal Data information that: Is about a living person Identifies a person whether by itself, or together with other information in the organisation's possession (or likely to come into its possession) Is in an electronic form or a structured manual file Sensitive Personal Data information about: Racial or ethnic origin Physical or mental health condition Religious beliefs Sexual life Political opinions Trade union membership Criminal convictions or allegations of any offence 4
5 Data controllers & processors Data controller The person who ultimately (alone or jointly) determines the purpose and manner in which any personal data is to be processed ie the Trustees of each pension scheme; also some service providers Data processor Any person who processes the data on behalf of a data controller eg scheme administrators, hosting providers Data processors have no direct obligations under the Act Controllers can be held liable for the actions of their data processors and any joint data controllers. Controllers are required under the Act to undertake due diligence and include key provisions in agreements with processors 5
6 Who are Data Controllers? Trustees Professional service providers where duties not just to Trustees ICO Guidance Actuaries Institute and Faculty of Actuaries Lawyers Accountants/auditors Not pension administrators Product providers? 6
7 The eight data protection principles Data controllers must ensure that all personal data is: 1) Processed fairly and lawfully 2) Processed for limited purposes 3) Adequate, relevant and not excessive 4) Accurate and up-to-date 5) Not kept for longer than necessary 6) Processed in accordance with data subjects' rights 7) Kept secure 8) Not transferred outside the EEA unless the data will be adequately protected 7
8 Monetary penalties Power given to ICO in 2010 If serious breach of the Act Controller knew or ought to know could cause serious detriment Overwhelming majority of monetary penalties (and the highest) for data security breaches Many fines on controllers when it was their processors at fault 8
9 Transferring data outside the EEA the Eighth Principle No transfer outside the EEA unless adequate protection Why does this matter? What is adequate? Approved countries US Safe Harbor EC approved Model Clauses The ICO's position 9
10 Contractual protections Must always have agreement when appointing processor Only completely safe course Almost unamended Model Clauses Initial processor within Europe Supplemented by: Right to require repatriation of data Specific provisions for dealing with data breach 10
11 Data Security Risks the Seventh Principle Principle 7 requires the taking "appropriate technical and organisational measures against unauthorised or unlawful processing of data and against accidental loss or destruction of, or damage to, personal data" Highest ICO fines to date have concerned data security (or lack of it) and damage to reputation is a major risk Could be caused by: Poor access control (physical and virtual) allowing unauthorised access Forwarding papers to home account Loss of unencrypted laptop or other device, such as a memory stick Sending to wrong address Sending "cc" rather than "bcc" s to members Administrator hosts data on faulty virtual servers 11
12 Data Security - Solutions Properly implemented data security policy Nominated individual with overall responsibility for data security Technical security applied to data held electronically eg encryption, password protection, rules about downloading to mobile devices Physical security to data in paper form and electronic devices on which data is stored Vetting and training those who have access to personal data Access limited to that which is necessary Secure disposal of hard copy data Secure deletion of electronic data Appropriate due diligence before using service providers Contracts with service providers 12
13 Data security the Seventh Principle When appointing processors controllers are in breach of the Act unless: Upfront and ongoing due diligence into processor's security measures Security questionnaire Written contract requiring Only to process on controller's instructions To comply with the Seventh Principle General obligation not enough 13
14 Data security the Seventh Principle (cont'd) Other strongly advisable contractual clauses Immediate notification of data security breach Remedial actions on security breach Audit rights Sub-contractor approval Responding to Data Subject Access Requests Indemnities for losses Restrictions on processing outside the EEA Deletion of data on termination 14
15 ICO's Core Security Requirements Protection in transit, at rest, in use Encryption Hard drive of laptop Memory sticks Weakest link Bring Your Own Device ICO Guidance on commonest IT security mistakes 15
16 Passwords Password storage Use robust hashing and salting Complexity of password At least ten digits Numbers, letters (upper and lower case), and special symbols 16
17 Data Security Using Secure Passwords Chara cters Numbers only Upper case or lower case letters Upper case and lower case letters Numbers, upper case and lower case letters Numbers, upper case, lower case and symbols 4 Instantly Instantly Instantly Instantly Instantly 5 Instantly Instantly Instantly 3 seconds 10 seconds 6 Instantly Instantly 8 seconds 3 minutes 13 minutes 7 Instantly Instantly 5 minutes 3 hours 17 hours 8 Instantly 13 minutes 3 hours 10 days 57 days 9 4 seconds 6 hours 4 days 1 year 12 years seconds 6 days 169 days 106 years 928 years 12 1 hour 12 years 600 years 108k years 5m years 14 4 days 8k years 778k years 1bn years 5bn years 16 1 year 512m years 1bn years 6tn years 193tn years years 3bn years 1tn years 23qd years 1qt years 17
18 Managing a significant data breach Need to move fast Actions to minimise adverse effects Notifying members the ICO the police the pensions regulator Remedial actions Best time to think about how to handle a major data loss/breach Before the event Policy on handling data breaches Importance of co-operation of service providers 18
19 Notifications To the ICO No obligation under the Act ICO guidance notify if: Potential detriment to affected individuals Large amount of data Particularly sensitive (even if small amount) Significant damage or distress to individuals Consequence of non-notification higher penalty Consequences of notification ICO will investigate data protection compliance Security measures Contracts 19
20 Notifications To individuals If notification will help them protect themselves eg against identity theft If notify individuals, notify ICO? To the Pensions Regulator if: Breach of the law Likely to be of material significance to the Pensions Regulator 20
21 Draft EU Data Protection Regulation Implementation unlikely before 2017 Key elements Data processors will also have direct obligations Mandatory breach notification to data protection regulator without undue delay Mandatory notification to individuals unless data unintelligible to unauthorised user Maximum fines - 100,000,000 or 5% of global turnover 21
22 Key takeaways Ensure security of own processing Upfront and regular audits of processor security measures Contracts providing adequate protection Policies and training Data breach response policy 22
23 Contact Information Caroline Egan Consultant
24 Worldwide Locations (including independent network firms) 24
Little Marlow Parish Council Registration Number for ICO Z3112320
Data Protection Policy Little Marlow Parish Council Registration Number for ICO Z3112320 Adopted 2012 Reviewed 23 rd February 2016 Introduction The Parish Council is fully committed to compliance with
More informationData Protection in Ireland
Data Protection in Ireland 0 Contents Data Protection in Ireland Introduction Page 2 Appointment of a Data Processor Page 2 Security Measures (onus on a data controller) Page 3 8 Principles Page 3 Fair
More informationThe potential legal consequences of a personal data breach
The potential legal consequences of a personal data breach Tue Goldschmieding, Partner 16 April 2015 The potential legal consequences of a personal data breach 15 April 2015 Contents 1. Definitions 2.
More informationData Protection and Information Security. Procedure for reporting a breach of data security. April 2013
Data Protection and Information Security Procedure for reporting a breach of data security April 2013 Page 1 of 6 Created on: 01/04/2009 Contents 1 Introduction... 3 2 Data Classification... 3 3 What Is
More informationData Protection Act. Privacy & Security in the Information Age. April 26, 2013. Ministry of Communications, Ghana
Data Protection Act Privacy & Security in the Information Age April 26, 2013 Agenda Privacy in The Information Age The right to privacy Why We Need Legislation Purpose of the Act The Data Protection Act
More informationDATA PROTECTION POLICY
Reference number Approved by Information Management and Technology Board Date approved 14 th May 2012 Version 1.1 Last revised N/A Review date May 2015 Category Information Assurance Owner Data Protection
More informationGUIDE TO THE ISLE OF MAN DATA PROTECTION ACT. CONTENTS PREFACE 1 1. Background 2 2. Data Protections Principles 3 3. Notification Requirements 4
GUIDE TO THE ISLE OF MAN DATA PROTECTION ACT CONTENTS PREFACE 1 1. Background 2 2. Data Protections Principles 3 3. Notification Requirements 4 PREFACE The following provides general guidance on data protection
More informationCorporate ICT & Data Management. Data Protection Policy
90 Corporate ICT & Data Management Data Protection Policy Classification: Unclassified Date Created: January 2012 Date Reviewed January Version: 2.0 Author: Owner: Data Protection Policy V2 1 Version Control
More informationSo the security measures you put in place should seek to ensure that:
Guidelines This guideline offers an overview of what the Data Protection Act requires in terms of information security and aims to help you decide how to manage the security of the personal data you hold.
More informationRick Parsons Information Governance Officer County Hall 01865 323593 rick.parsons@oxfordshire.gov.uk
Rick Parsons Information Governance Officer County Hall 01865 323593 rick.parsons@oxfordshire.gov.uk 1 THE DATA PROTECTION ACT 1998 2 Requirements of the Act Roles & Responsibilities Best Practice 3 The
More informationData Security and Extranet
Data Security and Extranet Derek Crabtree Schools ICT Support Manager derek.crabtree@merton.gov.uk Target Operating Model 2011 Merton Audit Organisation name: London Borough of Merton Periodic plan date:
More informationMerthyr Tydfil County Borough Council. Data Protection Policy
Merthyr Tydfil County Borough Council Data Protection Policy 2014 Cyfarthfa High School is a Rights Respecting School, we recognise the importance of ensuring that the United Nations Convention of the
More informationROEHAMPTON UNIVERSITY DATA PROTECTION POLICY
ROEHAMPTON UNIVERSITY DATA PROTECTION POLICY Originated by: Data Protection Working Group: November 2008 Impact Assessment: (to be confirmed) Recommended by Senate: 28 January 2009 Approved by Council:
More informationData protection policy
Data protection policy Introduction 1 This document is the data protection policy for the Nursing and Midwifery Council (NMC). 2 The Data Protection Act 1998 (DPA) governs the processing of personal data
More informationHuman Resources Policy documents. Data Protection Policy
Policy documents Aims of the Policy apetito is committed to meeting its obligations under data protection law. As a business, apetito handles a range of Personal Data relating to its customers, staff and
More informationData Protection Policy
Data Protection Policy September 2015 Contents 1. Scope 2. Purpose 3. Data protection roles 4. Staff training and guidance 5. About the Data Protection Act 1998 6. Policy 7. The Information Commissioner's
More informationDATA SECURITY BREACH MANAGEMENT POLICY AND PROCEDURE
DATA SECURITY BREACH MANAGEMENT POLICY AND PROCEDURE 1. INTRODUCTION Annex C 1.1 Surrey Heath Borough Council (SHBC) processes personal data and must respond appropriately against unauthorised or unlawful
More informationPolicy and Procedure for approving, monitoring and reviewing personal data processing agreements
Policy and Procedure for approving, monitoring and reviewing personal data processing agreements 1 Personal data processing by external suppliers, contractors, agents and partners Policy and Procedure
More informationNotification of data security breaches to the Information Commissioner s
ICO lo Notification of data security breaches to the Information Commissioner s Data Protection Act Contents Overview... 2 What the DPA says... 2 Reporting a breach... 2 Potential detriment to data subjects...
More informationtechnical factsheet 176
technical factsheet 176 Data Protection CONTENTS 1. Introduction 1 2. Register with the Information Commissioner s Office 1 3. Period protection rights and duties remain effective 2 4. The data protection
More informationHERTSMERE BOROUGH COUNCIL
HERTSMERE BOROUGH COUNCIL DATA PROTECTION POLICY October 2007 1 1. Introduction Hertsmere Borough Council ( the Council ) is fully committed to compliance with the requirements of the Data Protection Act
More informationAlixPartners, LLP. General Data Protection Statement
AlixPartners, LLP General Data Protection Statement GENERAL DATA PROTECTION STATEMENT 1. INTRODUCTION 1.1 AlixPartners, LLP ( AlixPartners ) is committed to fulfilling its obligations under the data protection
More informationPolicy Document Control Page
Policy Document Control Page Title Title: Data Protection Policy Version: 3 Reference Number: CO59 Keywords: Data, access, principles, protection, Act. Data Subject, Information Supersedes Supersedes:
More informationSecurity breaches: A regulatory overview. Jonathan Bamford Head of Strategic Liaison
Security breaches: A regulatory overview Jonathan Bamford Head of Strategic Liaison Security breaches and the DPA Data controllers security obligation - principle 7 of the DPA o Appropriate technical and
More informationWebinar Questions Local Government Data Security Help Improve Your Compliance, 30 July 2015
Webinar Questions Local Government Data Security Help Improve Your Compliance, 30 July 2015 Here are the answers to the questions we were asked during the webinar. There are a few questions we are still
More informationData Compliance. And. Your Obligations
Information Booklet Data Compliance And Your Obligations What is Data Protection? It is the safeguarding of the privacy rights of individuals in relation to the processing of personal data. The Data Protection
More informationData Protection and Community Councils Briefing Note
Data Protection and Community Councils Briefing Note This briefing note has been prepared in response to specific queries raised by Community Councils in Marr in relation to their Data Protection requirements.
More informationInformation Governance Policy
Information Governance Policy 1 Introduction Healthwatch Rutland (HWR) needs to collect and use certain types of information about the Data Subjects who come into contact with it in order to carry on its
More informationDATA PROTECTION ACT 1998 COUNCIL POLICY
DATA PROTECTION ACT 1998 COUNCIL POLICY Page 1 of 5 POLICY STATEMENT Blackpool Council recognises the need to fully comply with the requirements of the Data Protection Act 1998 (DPA) and the obligations
More informationIndex. Definitions. What is Data Protection? Rights of Individuals. The 8 Principles of Data Protection
Data Protection Awareness Based on DIT s Data Protection Policy, the Data Protection Acts, 1988 & 2003 and guidance from the Office of the Data Protection Commissioner Index Definitions What is Data Protection?
More informationHow To Understand The Data Protection Act
DATA PROTECTION ACT 2002 The Basics Purpose of the Act Balance the rights of an individual with an organisation s legitimate need to process personal data Promote openness and transparency Establish and
More informationUniversity of Limerick Data Protection Compliance Regulations June 2015
University of Limerick Data Protection Compliance Regulations June 2015 1. Purpose of Data Protection Compliance Regulations 1.1 The purpose of these Compliance Regulations is to assist University of Limerick
More informationCORK INSTITUTE OF TECHNOLOGY
CORK INSTITUTE OF TECHNOLOGY DATA PROTECTION POLICY APPROVED BY GOVERNING BODY ON 30 APRIL 2009 INTRODUCTION Cork Institute of Technology is committed to a policy of protecting the rights and privacy of
More informationData Protection and Data security Policy
Data Protection and Data security Policy Statement of policy and purpose of Policy 1. Somer Valley Community Radio Ltd (the Employer) is committed to ensuring that all personal information handled by us
More informationProtection. Code of Practice. of Personal Data RPC001147_EN_WB_L_1
Protection of Personal Data RPC001147_EN_WB_L_1 Table of Contents Data Protection Rules Foreword From the Data Protection Commissioner Introduction From the Chairman Data Protection Responsibility of Employees
More informationData Protection Policy
1 Data Protection Policy Version 1: June 2014 1 2 Contents 1. Introduction 3 2. Policy Statement 3 3. Purpose of the Data Protection Act 1998 3 4. The principles of the Data Protection Act 1998 4 5 The
More informationThe Manitowoc Company, Inc.
The Manitowoc Company, Inc. DATA PROTECTION POLICY 11FitzPatrick & Associates 4/5/04 1 Proprietary Material Version 4.0 CONTENTS PART 1 - Policy Statement PART 2 - Processing Personal Data PART 3 - Organisational
More informationScottish Rowing Data Protection Policy
Revision Approved by the Board August 2010 1. Introduction As individuals, we want to know that personal information about ourselves is handled properly, and we and others have specific rights in this
More informationDATA PROTECTION POLICY
DATA PROTECTION POLICY Version 1.3 April 2014 Contents 1 POLICY STATEMENT...2 2 PURPOSE....2 3 LEGAL CONTEXT AND DEFINITIONS...2 3.1 Data Protection Act 1998...2 3.2 Other related legislation.....4 3.3
More informationData and Cyber Laws Up-date 9 July 2015
Data and Cyber Laws Up-date 9 July 2015 Janine Regan Alexia Zuber Viktoria Protokova Simon Holdsworth charlesrussellspeechlys.com Topics Updates on the key aspects of, and commentary on, the proposed GDPR
More informationInformation security incident reporting procedure
Information security incident reporting procedure Responsible Officer Author Date effective from 2009 Ben Bennett, Business Planning & Resources Director Julian Lewis, Governance Manager Date last amended
More informationNavigating the Privacy Law Landscape - US and Europe
21 January, 2015 Navigating the Privacy Law Landscape - US and Europe Roberta Anderson, Partner, K&L Gates, Pittsburgh Friederike Gräfin von Brühl, Senior Associate, K&L Gates, Berlin Etienne Drouard,
More informationOBJECTS AND REASONS. (a) the regulation of the collection, keeping, processing, use or dissemination of personal data;
OBJECTS AND REASONS This Bill would provide for (a) the regulation of the collection, keeping, processing, use or dissemination of personal data; (b) the protection of the privacy of individuals in relation
More informationData Protection. Policy and Application July 2009
Data Protection Policy and Application July 2009 Produced for staff of the House of Commons Service by the Department of Resources Information Rights and Information Security (IRIS) Service Data Policy:
More informationUNIVERSITY OF ABERDEEN POLICY ON DATA PROTECTION
UNIVERSITY OF ABERDEEN POLICY ON DATA PROTECTION The Data Protection Act 1998 (DPA) was passed in order to implement the EU Data Protection Directive (95/46/EC) and applies to all data relating to, and
More informationDATA PROTECTION POLICY
DATA PROTECTION POLICY Approval date: June 2014 Approved by: Board Responsible Manager: Executive Director of Resources Next Review June 2016 Data Protection Policy 1. Introduction Data Protection Policy
More informationData Protection Policy
Data Protection Policy CONTENTS Introduction...2 1. Statement of Intent...2 2. Fair Processing or Privacy Statement...3 3. Data Uses and Processes...4 4. Data Quality and Integrity...4 5. Technical and
More informationDATA PROTECTION AUDIT GUIDANCE
DATA PROTECTION AUDIT GUIDANCE CONTENTS Section I: Section II: Audit of Processing of Personal Data Audit Procedure Appendices: A B C D E Audit Form List of Purposes List of data subjects List of data
More information2. Scope 2.1 This policy covers all the activities and processes of the University that uses personal information in whatever format.
University of Westminster Personal Data Protection Policy For Compliance with the Data Protection Act 1998 1. Background 1.1 The Data Protection Act 1998 (DPA) defines personal data as data and information
More informationProtection. Code of Practice. of Personal Data RPC001147_EN_D_19
Protection of Personal Data RPC001147_EN_D_19 Table of Contents Data Protection Rules Foreword From the Data Protection Commissioner Introduction From the Chairman Data Protection Rules Responsibility
More informationData Protection Policy
Data Protection Policy Responsible Officer Author Date effective from July 2009 Ben Bennett, Business Planning & Resources Director Julian Lewis, Governance Manager Date last amended December 2012 Review
More informationDATA AND PAYMENT SECURITY PART 1
STAR has teamed up with Prevention of Fraud in Travel (PROFiT) and the Fraud Intelligence Network (FIN) to offer our members the best advice about fraud prevention. We recognise the increasing threat of
More informationThe supplier shall have appropriate policies and procedures in place to ensure compliance with
Supplier Instructions for Processing of Personal Data 1 PURPOSE SOS International has legal and contractual obligations on the matters of data protection and IT security. As a part of these obligations
More informationOffice of the Data Protection Commissioner of The Bahamas. Data Protection (Privacy of Personal Information) Act, 2003. A Guide for Data Controllers
Office of the Data Protection Commissioner of The Bahamas Data Protection (Privacy of Personal Information) Act, 2003 A Guide for Data Controllers 1 Acknowledgement Some of the information contained in
More informationThe Data Protection Landscape. Before and after GDPR: General Data Protection Regulation
The Data Protection Landscape Before and after GDPR: General Data Protection Regulation Data Protection regulations across Europe Current regulations & guidance European Directives 95/46/EC (Data Protection)
More informationPrivacy and Electronic Communications Regulations
ICO lo Notification of PECR security breaches Privacy and Electronic Communications Regulations Contents Introduction... 2 Overview... 2 Relevant security breaches... 3 What is a service provider?... 3
More informationIncident reporting procedure
Incident reporting procedure Responsible Officer Author Date effective from Aug 2009 Date last amended Aug 2009 Review date July 2012 Ben Bennett, Business Planning & Resources Director Julian Lewis, Governance
More informationDATA PROTECTION POLICY
DATA PROTECTION POLICY Rev No. 0 New Document 1 2 3 4 5 6 7 Revision Status Details of Amendments Name Date Update of College DPA statement New Reference to Appendix 4 Staff Guidelines ESF document retention
More informationBRITISH COUNCIL DATA PROTECTION CODE FOR PARTNERS AND SUPPLIERS
BRITISH COUNCIL DATA PROTECTION CODE FOR PARTNERS AND SUPPLIERS Mat Wright www.britishcouncil.org CONTENTS Purpose of the code 1 Scope of the code 1 The British Council s data protection commitment and
More informationA Guide to Understanding Group Risk Insurance
A Guide to Understanding Group Risk Insurance This guide has been produced by Group Risk Development (GRiD) with the support of the Chartered Institute of Procurement and Supply (CIPS). CIPS members can
More informationFIRST DATA CORPORATION PROCESSOR DATA PROTECTION STANDARDS
FIRST DATA CORPORATION PROCESSOR DATA PROTECTION STANDARDS As a world leader in electronic commerce and payment services, First Data Corporation and its subsidiaries ( First Data entity or entities ),
More informationPersonal data - Personal data identify an individual. For example, name, address, contact details, date of birth, NHS number.
Background The Data Protection Act 1998 i came into force in March 2000 and is followed by all NHS employed staff via their policies and procedures. The act applies to all personal, identifiable information
More informationData Protection Good Practice Note
Data Protection Good Practice Note This explanatory document explains what charities and voluntary organisations need to do to comply with the Data Protection Act 1988 as amended by the Data Protection
More informationData Protection Policy
Data Protection Policy Prepared By: Malkiat Thiarai Head of Corporate Information Management Date of Publication: 23/01/2013 Version: 5.0 Classification: Not Protectively Marked Page 1 Table of Contents
More informationPAPER RECORDS SECURE HANDLING AND TRANSIT POLICY
PAPER RECORDS SECURE HANDLING AND TRANSIT POLICY CORPORATE POLICY Document Control Title Paper Records Secure Handling and Transit Policy Author Information Governance Manager ** Owner SIRO/CIARG Subject
More informationData controllers and data processors: what the difference is and what the governance implications are
ICO lo : what the difference is and what the governance implications are Data Protection Act Contents Introduction... 3 Overview... 3 Section 1 - What is the difference between a data controller and a
More informationA practical guide to IT security
Data protection A practical guide to IT security Ideal for the small business The Data Protection Act states that appropriate technical and organisational measures shall be taken against unauthorised or
More informationOUTSOURCING, HOSTING AND DATA PRIVACY ISSUES
OUTSOURCING, HOSTING AND DATA PRIVACY ISSUES 4 April 2013 James Castro-Edwards Solicitor Monica Salgado Advogada / Portuguese Lawyer OUR TEAM Speechly Bircham is an ambitious, full-service law firm with
More informationDealing with data breaches in Europe and beyond
Dealing with data breaches in Europe and beyond Karin Retzer and Joanna Łopatowska Morrison & Foerster LLP www.practicallaw.com/6-505-9638 The use of increasingly advanced technology means that the ways
More informationDublin City University
Dublin City University Data Protection Policy Data Protection Policy Contents Purpose... 1 Scope... 1 Data Protection Principles... 1 Disclosure of Personal Data... 2 Summary of Responsibilities... 3 Rights
More informationQUEENSLAND COUNTRY HEALTH FUND. privacy policy. Queensland Country Health Fund Ltd ABN 18 085 048 237. better health cover shouldn t hurt
QUEENSLAND COUNTRY HEALTH FUND privacy policy Queensland Country Health Fund Ltd ABN 18 085 048 237 better health cover shouldn t hurt 1 2 contents 1. Introduction 4 2. National Privacy Principles 5 3.
More information1.2 Scope This policy and guidance applies to all University staff, students and others who use or process any personal information.
MANCHESTER METROPOLITAN UNIVERSITY DATA PROTECTION POLICY This policy should be read in conjunction with the Data Protection Guidance, which is attached as: Appendix A Dealing with Personal Data Appendix
More informationwww.neelb.org.uk Web Site Download Carol Johnston
What I need to know about data protection and information security when purchasing a service that requires access to my information by a third party. www.neelb.org.uk Web Site Download Carol Johnston Corporate
More informationData Protection Act 1998 The Data Protection Policy for the Borough Council of King's Lynn & West Norfolk
Data Protection Act 1998 The for the Borough Council of King's Lynn & West Norfolk 1 Contents Introduction 3 1. Statement of Intent 4 2. Fair Obtaining I Processing 5 3. Data Uses and Processes 6 4. Data
More informationINFORMATION GOVERNANCE HANDBOOK
INFORMATION GOVERNANCE HANDBOOK SECTION ONE Author Tracey Burrows Role Information Governance Manager (CSCSU) Date / Version February 2015 Version FINAL V1.0 Approved by IM&T Board Date 27 February 2015
More informationData Protection for Charities
Data Protection for Charities CFG 15 May 2014 Overview Overview and key definitions The data protection principles Fair and lawful processing Data security and outsourcing Rights of data subjects Recent
More informationSCOTLAND S COMMISSIONER FOR CHILDREN AND YOUNG PEOPLE STANDARD CONDITIONS OF CONTRACT FOR SERVICES
SCOTLAND S COMMISSIONER FOR CHILDREN AND YOUNG PEOPLE STANDARD CONDITIONS OF CONTRACT FOR SERVICES 1 1 Definitions In these conditions:- We means Scotland s Commissioner for Children and Young People,
More informationHuman Resources and Data Protection
Human Resources and Data Protection Contents 1. Policy Statement... 1 2. Scope... 2 3. What is personal data?... 2 4. Processing data... 3 5. The eight principles of the Data Protection Act... 4 6. Council
More informationDemystifying Cyber Insurance. Jamie Monck-Mason & Andrew Hill. Introduction. What is cyber? Nomenclature
Demystifying Cyber Insurance Jamie Monck-Mason & Andrew Hill Introduction What is cyber? Nomenclature 1 What specific risks does cyber insurance cover? First party risks - losses arising from a data breach
More informationData protection compliance checklist
Data protection compliance checklist What is this checklist for? This checklist is drawn up on the basis of analysis of the relevant provisions of European law. Although European law aims at harmonizing
More informationThe HR Skinny: Effectively managing international employee data flows
The HR Skinny: Effectively managing international employee data flows Topics we will cover today Laws affecting HR data flows HR international data protection challenges and strategic solutions Case study
More informationData Protection. Processing and Transfer of Personal Data in Kvaerner. Binding Corporate Rules Public Document
Data Protection Processing and Transfer of Personal Data in Kvaerner Binding Corporate Rules Public Document 1 of 19 1 / 19 Table of contents 1 Introduction... 4 1.1 Scope... 4 1.2 Definitions... 4 1.2.1
More informationHampstead Parochial CofE Primary School Data Protection Policy Spring 2015
Hampstead Parochial CofE Primary School Data Protection Policy Spring 2015 1. Introduction and Scope 1.1 The Data Protection Act 1998 is the law that protects personal privacy and applies to any school
More informationAn overview of UK data protection law
An overview of UK data protection law Our team Vinod Bange Partner +44 (0)20 7300 4600 v.bange@taylorwessing.com Graham Hann Partner +44 (0)20 7300 4839 g.hann@taylorwessing.com Chris Jeffery Partner +44
More informationJohn Leggott College. Data Protection Policy. Introduction
John Leggott College Data Protection Policy Introduction The College needs to keep certain information about its employees, students and other users to allow it to monitor performance, achievements, and
More informationData Protection Policy June 2014
Data Protection Policy June 2014 Approving authority: Consultation via: Court Audit and Risk Committee, University Executive, Secretary's Board, Information Governance and Security Group Approval date:
More informationCloud Computing Legal Considerations for Data Controllers
Cloud Computing Legal Considerations for Data Controllers CLOUD COMPUTING LEGAL CONSIDERATIONS FOR DATA CONTROLLERS What is cloud computing and why is it relevant? Cloud computing can be described as technology
More informationCOMMISSION REGULATION (EU) No /.. of XXX
EUROPEAN COMMISSION Brussels, XXX [ ](2013) XXX draft COMMISSION REGULATION (EU) No /.. of XXX on the measures applicable to the notification of personal data breaches under Directive 2002/58/EC on privacy
More informationStandard conditions of purchase
Standard conditions of purchase 1 OFFER AND ACCEPTANCE 2 PROPERTY, RISK & DELIVERY 3 PRICES & RATES The Supplier shall provide all Goods and Services in accordance with the terms and conditions set out
More informationNIGB. Information Governance Untoward Incident Reporting and Management Advice for Local Authorities
Information Governance Untoward Incident Reporting and Management Advice for Local Authorities March 2013 Contents Page 1. The Role of the NIGB.....3 2. Introduction...4 3. Background Information...6 4.
More informationOn the edge Lexis PSL Restructuring & Insolvency
On the edge Lexis PSL Restructuring & Insolvency Data protection law for insolvency practitioners November 2014 Welcome to your third edition of On the edge, a series of guides highlighting a selection
More informationPolicy and Procedure Title: Maintaining Secure Learner Records Policy No: CCTP1001 Version: 1.0
PROVIDER NAME: POLICY AREA: College of Computing Technology (CCT) Standard 10: Information Management, Student Information System & Data Protection Policy and Procedure Title: Maintaining Secure Learner
More informationGuidelines on Data Protection. Draft. Version 3.1. Published by
Guidelines on Data Protection Draft Version 3.1 Published by National Information Technology Development Agency (NITDA) September 2013 Table of Contents Section One... 2 1.1 Preamble... 2 1.2 Authority...
More informationCorporate Policy. Data Protection for Data of Customers & Partners.
Corporate Policy. Data Protection for Data of Customers & Partners. 02 Preamble Ladies and gentlemen, Dear employees, The electronic processing of virtually all sales procedures, globalization and growing
More informationData protection issues on an EU outsourcing
Data protection issues on an EU outsourcing Saam Golshani, Alastair Gorrie and Diego Rigatti, Orrick Herrington & Sutcliffe www.practicallaw.com/8-380-8496 Outsourcing can mean subcontracting a process
More informationData Protection Policy A copy of this policy is published in the following areas: The school s intranet The school s website
Data Protection Policy A copy of this policy is published in the following areas: The school s intranet The school s website Date created: November 2015 Date for review: July 2016 Created by: Mark Vanstone,
More informationInformation Governance
CONTROLLED Information Governance Caldicot Version-Workbok Non Caldicott Version - Workbook Version 12 January 2015 40 1 Don t Get Bitten by the Data Demon Notes Using this Workbook The objective of this
More informationData Protection Procedures
Data Protection Procedures PROCEDURE OVERVIEW: This Procedure outlines Down District Council s ( the Council ) commitment to the Data Protection Act 1998 ( the Act ) and provides a framework for the Council
More informationThe Manchester College
The Manchester College The Manchester College Produced by TMC Prin DataProtect pol v1 11/2010 All rights reserved; no part of this publication may be photocopied, recorded or otherwise reproduced, stored
More information