DATE December 18, 2019 2:07 pm POSTED BY CATEGORY Blog

Subject Access Request as a Service

The Outsourced DPO has seen an increasing number of subject access requests submitted via a third-party service sites making for an interesting trend.  In the last few months there seems to have been an increasing number of web sites and apps offering to submit subject access requests on behalf of...
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DATE December 10, 2019 1:52 pm POSTED BY CATEGORY Blog

Data Protection Registration and Fees

There seems to be some confusion out there about the requirement to register with the ICO – the Outsourced DPO was asked about this on four separate occasions last week. If you cast your mind back, articles 18 and 19 of the Data Protection Directive (Directive 95/46/EC) contained an obligation...
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DATE November 15, 2019 12:48 pm POSTED BY CATEGORY Blog

Beware software with no delete function

You may have missed the fine of €14½ million imposed by the data protection authority of Berlin on Deutsche Wohnen SE, a property management company who were found to use software systems that do not allow for the deletion of data.  This regulatory action resonated with the Outsourced DPO because...
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DATE June 21, 2019 8:51 am POSTED BY CATEGORY Data Protection

Outsourced SARs service

The Outsourced DPO remembers the very first subject access request he undertook on behalf of a client 12 or more years ago and since then has provided SAR support on many occasions.  Last week DPP attended the National Housing Federation’s governance conference in London and re-launched its SAR support service...
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DATE June 7, 2019 10:37 am POSTED BY CATEGORY Blog

GDPR in the fast lane.

The Outsourced DPO has often compared data protection law to driving within the speed limit but a phone call last night changed that perception. Driving home last night, the Outsourced DPO was mulling over a customer brief for a DPIA on a project involving facial recognition when he suddenly remembered...
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DATE May 20, 2019 8:20 am POSTED BY CATEGORY Data Protection

Am I allowed to outsource my DPO?

This question is cropping up time again and, as the Outsourced DPO, we are well placed to answer it! The early drafts of the GDPR contained different criteria for determining when the designation of a DPO was mandatory which included for example, organisations employing more than 250 people or processing...
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DATE March 18, 2019 10:49 am POSTED BY CATEGORY Data Protection

Brexit and the Privacy Shield

The following notes from Data Protection People expand upon the official UK Government guidance in Guidance – Data protection if there’s no Brexit deal – Published 13 September 2018. Brexit background The GDPR allows free movement of personal data throughout the European Economic Area (EEA). The EEA is made up...
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DATE January 17, 2019 11:00 am POSTED BY CATEGORY Data Protection

Outsourced DPO: DPIA revisited

The Outsourced DPO wrote a blog about Data Protection Impact Assessments (DPIA) last November shortly before the ICO revised their guidance. In this blog, we review the ICO’s updated guidance and share the Outsourced DPO’s experiences from auditing in the lovely Essex this week. It is actually very easy to...
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DATE January 9, 2019 9:50 am POSTED BY CATEGORY Data Protection

Data Protection and a no deal Brexit

Hard Brexit The Outsourced DPO has been looking at the impact of a hard Brexit for some of his clients – what a roller coaster ride that is. In her blog of 13th December, Elizabeth Denham stated that, “the Government has already made clear its intention to permit data to...
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