My ‘light bulb’ moment on the GDPR

On Tuesday 31 October, President Donald J Trump gave the executive order to release previously withheld files relating to the 1963 assassination of John F Kennedy.

Among the many black and white TV news clips of speeches made by JFK that I’ve been watching across several TV networks that are marking one of the darkest hours in American history, one sentence in particular struck a chord with me and perhaps many of you reading this too:

“In each of us there’s a private hope and dream which, if fulfilled, can be translated into benefit for everyone.”

That may sound like a lofty ideal, but I sincerely believe that as data protection professionals we all need to have the conviction to want to make a positive difference for both the company and organisation that we are part of as well as...

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Black, Asian and Minority Ethnic (BAME) 100 List – 2017

In order to establish the shortlist for the Board Talent Index from within the BAME community, executive recruitment firm Green Park applied a soft scoring method based on the criteria it believes separates REALmodels from other diverse leaders. These criteria focus on influencing positive change and development in business and are each graded out of 25.
The criteria:

R = Recognised: accredited for the good that they do

E = Extraordinary: not just achieved but excelled in their efforts

A = Authentic: known for being true to their undisputed origin

L = Leading: climbed the ladder of their organisations and achieved success


Once the REALmodel leaders are identified, the judges ratify the shortlists based on their own insights, the individual’s credibility and the profiles presented and t...
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Take a Chance on Me? Not worth the risk when it comes to the GDPR

The cost of compliance is much less than the price of failure.

To most readers of my blog, this adage may sound obvious, with respect to the General Data Protection Regulation (Regulation 2016/679). Nonetheless, it’s advice isn’t universally observed.

Some months ago, I was talking to a director of a well-known European financial services company about the impact Regulation 2016/679 would have on the business. But I wasn’t fully prepared for his response. “We can afford to pay the fines,” he said.

Wow!

There then followed a couple of seconds of silence as I composed myself. Had I really heard this or had I imagined it? Was it boastful, perhaps intended to impress or simply a bold statement of fact?

I remarked this was interesting...

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Do you still worship at the Temple of Big Data?

Major personal data breaches are happening at a rate of one a day – Equifax, BUPADeloitteNHSNottingham County CouncilIslington CouncilHCA Healthcare and many, many more. Wanna Cry? (I bet you do).

Do you live in fear of whether you’re next? It doesn’t have to be this way. We are transitioning to an era in which individuals have both the skills and the opportunities to choose how they manage and share their personal data to achieve a range of beneficial outcomes.

Digital evangelists like Stephen Deadman, Global Deputy Chief Privacy Officer at Facebook remains optimistic about the future, rather than terrified by it...

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Legality of Standard Contractual Clauses (SCC’s) hangs in the balance awaiting decision by CJEU

Ireland’s High Court has just ruled today (Tuesday 3 October 2017) that the decision to ban the use of Standard Contractual Clauses (SCC) by social media giants like Facebook, Microsoft and Google to transfer users’ personal data to the US must be initially decided by the Court of Justice of the European Union (CJEU).

Giving her judgment in open court, Irish High Court Judge Caroline Costello said: “I have decided to ask the Court of Justice for a preliminary ruling. European Union law guarantees a high level of protection to EU citizens…they are entitled to an equivalent high level of protection when their data is transferred outside of the European Economic Area.”

This of course looks like a spooky re-run of the Safe Harbor legal action brought by Max Schrems that resulted in the...

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Is processing personal data under ‘legitimate interest’ creepy or cool?

With less than 200 working days left before Regulation 2016/679 (General Data Protection Regulation) kicks in, a new global study published by the Centre for Information Policy Leadership – a privacy and security think tank – claims that organisations in the US, South America, Europe and Asia are confused about the legal basis for processing personal data under the GDPR.

A total of 223 senior managers of multi-national companies (57% Data Controllers, 43% Data Processors) responded to the survey across a wide variety of sectors including financial services, healthcare, pharma, technology and telecoms.

The authors of the study explored the reasons why organisations choose to rely on ‘legitimate interest’ as a basis for processing personal data and the reaction this could have among customer...

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RIP Walter Becker

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British data protection laws to criminalize breaches of GDPR

The British Government  has just announced (Monday 7 August 2017) that it will incorporate Directive 2016/679 (General Data Protection Regulation) along with specific derogations permitted under the GDPR as well as the Data Protection Law Enforcement Directive (DPLED) into UK law.

The move effectively repeals the current Data Protection Act 1998.

This follows a short consultation period (12 April – 10 May 2017) that called for views and which included 170 submissions from a wide range of professional bodies, legal and consumer groups, local government, technology companies, global organisations and academic institutions (7.1% of all respondents), including Henley Business School.

“Bringing EU law into our domestic law will ensure that we help to prepare the UK for the future after we ha...

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Interview with Liberum Investment Bank on the consequences of the GDPR for institutional investors

This is a short 5 minute filmed interview produced by Liberum Investment Bank for its clients in London and New York on the Directive 2016/679 (General Data Protection Regulation). Recorded in London in July 2017.

Copyright Liberum Investment Bank 2017.

 

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It’s time to press the delete key

One of the most important and fundamental principles of data protection under Regulation 2016/679 (GDPR) is the Principle of Minimisation. Arguably, it’s the one principle can help satisfy the need to manage security, data protection and privacy objectives, especially with respect to the Internet of Things (IoT).

Under Art.5(1)(c), GDPR, the Data Controller must ensure that ‘processing of personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.’ This is about ensuring that staff are only processing personal data in accordance with the purposes and once these have been satisfied, it’s safest to delete this personal data unless other legal grounds exist to hang on to it.

But the Principle of Minimisation is g...

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