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ICO guidance on Consent and GDPR

The Information Commissioner’s new guidance on Consent under the General Data Protection Regulation contains some useful guidance for universities and colleges in particular. On the question of which legal bases are available to universities and colleges – in particular whether they are included within the GDPR’s disapproval of consent and legitimate interests being used by […]

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Learning Analytics Dashboards

Learning analytics dashboards, like the class mark books that long preceded them, show tutors a lot of information about their students. That could be pretty intrusive, so should universities and colleges be asking students to consent before tutors look at their data? I don’t think so, both because the students most likely to benefit are […]

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Incident response, logfiles and the GDPR

The Article 29 Working Party has recently highlighted the importance of detecting and mitigating information security breaches. One of the key tools in doing this is logfiles: the European Court of Justice in Breyer v Germany recognised the role of web server logs, the Article 29 Working Party guidelines mention logs and network flow data. […]

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Research Provisions in the GDPR

Like the current Data Protection Act 1998, the General Data Protection Regulation (GDPR) will apply to any research involving data about identifiable living individuals. Also like the Act, the Regulation provides for adaptation in a couple of areas where this is needed to make such research possible. All processing of personal data needs a legal […]

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Are networks data processors?

As the GDPR approaches, several customer organisations have asked us if the Janet network will be offering a data processor contract. Presumably the idea is that the organisation that creates an IP packet is the data controller for the source IP address and that all the other networks that handle the packet on its journey […]

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IP Addresses, Privacy and the GDPR

It’s well-known that the General Data Protection Regulation says that IP addresses should be treated as personal data because they can be used to single out individuals for different treatment, even if not to actually identify them. In fact – as most organisations and network providers implement proxies, Network Address Translation (NAT) and other technologies […]

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Federated Authentication and the GDPR Principles

The General Data Protection Regulation’s Article 4(1) establishes six principles for any processing of personal data. It’s interesting to compare how federated authentication – where a student authenticates to their university/college, which then provides relevant assurances to the website they want to access – performs against those principles when compared with traditional direct logins to […]

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Publications

Why should non-EU organisations care about GDPR?

I was recently invited by EDUCAUSE to present a webinar on GDPR to their community of mostly North American universities and colleges. The number of participants indicates that European data protection law is a topic of interest. But the most common question was why, as non-EU organisations, they should care about GDPR. So I wrote […]

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Helpdesks: how long to keep information?

I’ve had a number of questions recently about how long help desks should keep personal data about the queries they receive. The correct answer is “as long as you need, and no longer”. But I hope the following examples of why you might need to keep helpdesk tickets are more helpful than that bare statement: […]

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Free Text and Data Protection

Collections of free text – whether in database fields, documents or email archives – present a challenge both for operations and under data protection law. They may contain personal data but it’s hard to find: whether you’re trying to use it, to ensure compliance with the data protection principles, or to allow data subjects to […]