The Information Commissioner’s Office has published a new article on how they are responding to the European Court’s Safe Harbor judgment. The overall message is that data controllers should take stock and not panic. While noting that the judgment does remove some of the former legal certainty, the ICO is “certainly not rushing to use […]
Article 29 Working Party on Safe Harbor
The Article 29 Working Party of European Data Protection supervisors has now published its response to the European Court’s ruling that the US-EU Safe Harbor agreement can no longer be relied upon when exporting personal data from the European Economic Area. Like the UK Information Commissioner’s earlier statement, they recognise that data exporters and US […]
Prevent Duty for FE/HE now in force
[Updated to include UCISA Model Regulations] After short debates in the Houses of Commons and Lords the legal duties on universities and colleges to address risks of radicalisation came into force on 18th September. The Government’s guidance is unchanged from the drafts published in July. In last week’s debates the Government again stressed that measures […]
Safe Harbor at the European Court
The European Court’s declaration today that the European Commission’s fifteen year old decision on the US Safe Harbor scheme is no longer reliable is another recognition that Data Protection requires continuing assessment, rather than one-off decisions. European regulators have been recommending for years that neither data controllers nor companies to which they export data should […]
The new European Data Protection Regulation is relevant to many areas of our work. Yesterday I had the opportunity to look at its likely effect on information security at a Jisc Special Interest Group meeting. For now, we’re still working from the three draft texts published by the European Commission in 2012, the Parliament in […]
Vulnerability handling – how organisations deal with reports of security weaknesses in their software and systems – is a field that has developed a lot in my time working for Janet. When I started most organisations received reports and fixed vulnerabilities on an ad hoc basis, if at all. Now we have guidelines on policies, […]
A helpful comment on page 3 of the Information Commissioner’s discussion of the latest (Council) draft of the General Data Protection Regulation: We reiterate our view that there must be realistic alternatives to consent – for example ‘legitimate interests’ where the data processing is necessary to provide the goods or services that an individual has […]
The Information Commissioner has published updated and extended guidance on the use of the Data Protection Act’s “section 29” exemption, based on cases and wider experience. This exemption is often used to release personal information (such as computer or network logs) to the police or other authorities investigating crimes, so sections 33-52 in particular are […]
A Question of Trust?
A question that comes up from time to time when discussing federated access management is “how can I rely on another organisation to manage accounts for me?”. Federation saves services the trouble of managing user accounts by instead delegating the job to an external identity provider, but it’s entirely reasonable to think carefully about that. […]
Phishing exercises?
Recently I had a thought-provoking discussion on Twitter (thanks to my guides) on the practice of setting your users phishing tests: sending them e-mails that tempt them to do unsafe things with their passwords, then providing feedback. I’ve always been deeply ambivalent about this. Identifying phishing messages is hard (see how you do on OpenDNS’s […]