Posts related to the General Data Protection Regulation. There are a lot of these, so if you want to find out how GDPR affects a particular topic, it’s better to use the topic tag; if you want to know about implementing GDPR, then try “GDPR Howto”
With the GDPR having now been in force for more than six months, my talk at this week’s EUNIS workshop looked at some of the less familiar corners of the GDPR map. In particular, since EUNIS provided an international audience, I was looking for opportunities to find common, or at least compatible, approaches across the […]
I’ve been asked a number of times whether GDPR affects the sharing of information between incident response teams. This slideset from a recent RUGIT Security meeting discusses how GDPR encourages sharing to improve security, and provides a rule of thumb for deciding when the benefit of sharing justifies the data protection risk. Information Sharing and […]
At last week’s Jisc Security Conference I presented a talk on how we’ve assessed a couple of Jisc services (our Security Operations Centre and Penetration Testing Service) from a data protection perspective. The results have reassured us that these services create benefits rather than risks for Jisc, its customers and members, and users of the […]
An interesting observation made by a Dutch colleague earlier this week. The arrows in my standard model of learning analytics (here rearranged and recoloured to match the “swimlane” visualisation of the learning process) all mark “gatekeeper” points where information flow is filtered and reduced. Between Collection and Analysis there’s a necessity/relevance filter so that not […]
In developing our Data Protection Impact Assessment for the Janet Security Operations Centre we noted that our Penetration Testing service could involve high risks, but didn’t really fit the DPIA framework. Penetration tests are much smaller scale than the SOC; they are commissioned by individual Jisc customers, usually on only parts of their operations; and […]
Recently I’ve been presenting our suggested legal framework for learning analytics to audiences involved in teaching, rather than legal people. For that I’ve been trying out a different visualisation, which considers the teaching process as involving three layers: Teaching itself (red): during which we process the personal data that’s needed to help students learn. The […]
Alongside the 1995 Data Protection Directive (DPD) sat the 2002 ePrivacy Directive (ePD), explaining how the DPD should be applied in the specific context of electronic communications. In fact, particularly after it was amended in 2009, the ePD did a bit more than that, as it turned out to be a convenient place to insert […]
Over recent months the GDPR has given extra weight to concerns – originally expressed by regulators fifteen years ago – about public access to information about individual registrants of DNS domains. This article considers the use of this WHOIS data by those handling information security incidents, and why this represents a benefit, rather than a […]
Since there was a lot of interest in my keynote presentation at the EUNIS 2018 conference last week, this post collects together the slides and the blog posts that provide further analysis and discussion of the ideas: Slides LA and GDPR v0-07 How to do Learning Analytics under the GDPR The role(s) of Consent Incorporating […]
I’ve been trying to produce a visual image to capture the twelve steps to GDPR compliance. For details of the individual steps see: Awareness Data Protection by Design Information Lifecycle Audit Breach Notification Process [Article 29 Working Party guidance] Legal Basis [Information Commissioner guidance] Privacy Notices [Article 29 Working Party guidance] Individual Rights Processes (inc.subject […]