or LinkedIn here https://uk.linkedin.com/in/tonysmiththathousingitguy
 |
Last week I was out with an old friend I used to work with many years (& jobs ago), in Edinburgh. Over the last year he has been doing a lot of work around GDPR. Some of it with the adoption authorities, of which he has a particular link, due to a couple of adoptions, made in the late nineties.
We were talking about the many areas where the new GDPR rights cannot be invoked, due to other legal or similar constraint. For example around adoption, adoptee records must be retained for one hundred years legally. Even failed adoptee data, must be held for thirty years.
Clearly these are areas where new ‘Right To Be Forgotten’ etc, will have no effect.
Particularly around ‘Right To Be Forgotten’ / ‘Right to Erasure’, we talked around some scenarios. Where an integrated system is properly in place, (rather than a fragmented hotch-potch of spreadsheets, mixed systems with repeated variants of key data), this should not be such an onerous task.
So what is the basis for the request for erasure of personal data? There are several valid reasons, including withdrawal of consent, data no longer needed to fulfil purpose originally communicated, data subject objects to your processing and you have no overriding legitimate interest basis, or your use was a breach of GDPR.
If an organisation is contacted, can an individual totally be ‘forgotten’? For example, if an organisation is asked to remove all trace of a persons data and there are no legal, or other recognised impediments to that, to follow the full letter of the law, even that ‘request to remove’, should really be erased too.
That is fine, if it was a request from the correct person and details were checked and collaborated before deletion. All is well.
However, if it was not the ‘actual’ person, or a mistake was made and the wrong persons details were erased, how can that be conclusively proved subsequently, without holding audit, containing some details of that erased data, evidence that authenticated the individual? Its an interesting situation, which surely will occur to you or your organisation, before too long.
Could that customer/personal data be ‘taken out of processing’ for a set period, then to be totally deleted, in order to support this scenario? The litmus test, we agreed should always be, is this action ‘reasonable’ and proportionate to any current or potential impact on the data subject.
I would be interested to hear your take on this, as would my GDPR friend up in Scotland OBVs!
Related Post: Control your system configuration well and your KPIs will follow
 |
Catch the blog monthly archive at https://soundcloud.com/housingitguy/ |
_/_/_/_/_/_/_/_/
I would be pleased to connect with you on LinkedIn - http://uk.linkedin.com/in/tonysmiththathousingitguy Message me with any issues or queries, you would like to be explored in this blog. We generally receive a couple of suggestions each month.
Simple Minds – Don’t You Forget About Me.
(c) Tony Smith, Acutance Consulting www.acutanceconsulting.co.uk 07854-655009
Access a quick list of our Social Housing ICT blog posts here
Could we help you or your organisation? Our contact details are here , get in touch we will be pleased to chat about your problems and help with your organisation issues.
File Under: 360,1stTouch,4Js. , 07854655009 ,365Agile," """" ",,#UKHousing,#HousingDAY, #HomesForBritain,#InternetOfTenants, #Shout,1st Touch,3squared,Accuserv,Acutence,Aareon,Academy,ActiveH,AirWatch,Alignment,ALMO,Anite,Apex,ArchHouse,Archouse,asbestos, Asprey e-state pro,ActiveHousing,Asset Management,Aurora,Average IT Costs,App,Associates,ACL,Abritas,AMS,AX,aspireview,Agile365, BO,BPR,Browser Applications,Business Objects,Business Planning, Business Process Review,Business social networking, Blockwise, Block wise,BI,BancTec,BluTek,Bluebox, Castle,CBL,Cedar Open Accounts,Cx,Change,Cheaper Housing IT,Chics, CHR,Citrix,Civica,Clearview,CMS , CCS IT Keystone CCSIT,Civica Genero,Contractor Systems,CORE,CorVu,Cost Reductions,Covalent,CRM,Crystal Reports,CTI,CTX,Customer Relationship Management,Cashflow, COA,Coactiva,Codeman,Comino,Competitive Dialogue process,complex IT procurements,Component Accounting, Community Reward Services, Consilium, Consolidation, Consultancy,Consultant,Contact Manager,Context,CIH,Chartered Institute Of Housing,Cadcorp,Cerrus Saturn,convergeOne,CACI,CPL, CRS Director, Deeplake,Development Systems,Accuserve,Document Management,Documotive,datasystems , Microsoft dynamics GP 2013, DynamicAI, Dynamic AI, ECMK,EDRMS,England, English,EnterpriseBI,ERP Systems,ERP,Elmhurst,Estatecraft,EDM,ESRI,Exponential-e, Finance, Financial Systems, Financials, Factorwise,Facebook ,Footprint,Fusion, Getting best from,gotonysmith, Grasp,Grip,GeoSolveIT,GIS,GGP,Genero,GCloud,G-Cloud,HouSys,Housing software,HFI (Housing Financials interface),HG,Housemark survey,Housing Blueprint,Housemark,Housing Portfolio Management System, HRA,housingtITguy,Housing Support Pro,HousingSupportPro,Housing Options,Hometeam, Housing Group,hotpixuk, HousingIT,hotpix,Hardware,Hitex,Housing Contact Company,housing predictive analytics, Impact Response,iPayPro,implementations,iRobot,In House,InHouse,In4,InMotion, InMotion2016, InMotion2015, InMotion2016 , Exhibition, conference,Housing Management Consultant,Housing Management Consultants, Infoflow,Information Technology,Informix,inHouse,in-house workforce,Information@Work components, Innovation,Inside Housing,Internet Portal,Internetalia,Information Management Server,IMS, Invu,Ireland,Irish,Inphase , IT Budget,IT Training,iWorld, Innovation Group Apex,ITIL, In4Systems Promaster,IT,Insight, iSupport,iSupportPro, Keylogic,Keystone,Kirona,Kypera,Keypera Hometeam,Keyfax,Ledgers,Linkedin,Locality,Liquid Voice,MD ,Mr Void , MrVoid, Measuring Change,Mebus,Miracle,MISCS,mDesign,mobile functionality,mobile platform,Monopoly board images and pictures, Montal,MS Dynamics,MS Dynamics CRM2011,Miracle Software,MDM,Management,CRM2013,Reporting,MI,M3,MIS,MIS-AMS,Mobysoft, Northgate Codeman,Neighbourhoods and Communities,NPS,NPS Housing,NPS CRM,NPS Job Manager Mobile, Northgate,Notice,NROSH,NINTEX,NINTEX workflow,Natural Forms,Nintexworkflow,NPS ASSIST, OA,OGC Buying Solutions,Ohms,OJEU Limits,OmFax,Omniledger,Open source software,open tender,OpenHousing,Opti-time,Oracle,Orchard,Optitime DRS,Outsource and outsourcing,OpenContractor,ORS,OneServe, PIMMS Data Systems, Paloma,performance management systems,PfH, Pick,PIMMS,pimms4communities, Planned maintenance,People Value,Plus, Peoplevalue,Portfolio Management System, PM,Progress,Promaster,Proval,Pyramid,PRINCE2,prince,Pamwin,PlanForm, Propoints, Pro-Points,predictive analytics for housing, QL,QLX,Quiss,Qlikview, QueryView,Queryview reporting,Registered Providers,Registered Social Landlord,Rent Increase Freezes,Repairfinder,Reporting,Reports,ROCC,RobotAutomation,Rave Technologies (India) PVT Limited, Rocket,RPs,RSL,Reality,ReAct,reidmark,RM865, Saffron,SAP,Scots, "Social Housing IT",Social Housing ICT, Scottish,Scenario, Scotland,SDM,sector,TonySmithHou,Safron,Server Virtualisation,servicing, Servitor,Sharepoint, Simdel,Simdell,SimPro,Sim Pro,Slash and Burn,Social Media,Software,SQL Open Housing,SQL Reporting Services,SQL reporting services,SQL Server,Star rating,Stores and Stock,Strategic Asset Management,Sunguard ,Surveys,Sx3,System alignment,Symatrix Human Capital Management, TonySmithHousing, Systemwise,SM,Sequoa,Serros,SP,Scout,score,Swordfish,Serengeti,SOTI,southview,Sunguard,Service Charges,Spotlight Service, Spotlightservice, SunAccounts, Social Housing Software Applications, Template,Task,Terminal Services, tonys , tonysm , tonysmi , tonysmith, tonysmitht, gotonysmith, tableau Business Dashboards, tonysmithth, tonysmiththa, tonysmiththat, tonysmiththath, tonysmiththatho, tonysmiththathou, tonysmiththathous, tonysmiththathousi, tonysmiththathousin, tonysmiththathousing,Tony Smith That,Tony Smith That Housing IT Guy,TonySmith that housing IT, guy,tonysmiththathousing, tonysmiththathousinguy,tony smith housing guy,sharepoint, share point, SHBVN, Three Star,Today,Total repairs,Tribal,Twitter,U2, tonysmith , tonysmiththat , thathousing , thathousingIT , thathousingITguy, TED,Tagish Casework,TP Tracker,Telecetera,Tagra,Trace, Totalmobile, Total Mobile, UniClass Enterprise,Unidata,Universal Housing,Universalcredit, universal credit, universal credits,UC,Universe,Unrest, UK, United Kingdom ,Ukhousing,UK Housing, Van Stock,Voice and data,Vantage Sentinel,verse one,verseone,vWork,Version One,Visualmetrics,Valueworks,Voluntas, Wales,Welsh,Windows Server,Workflow and tasking,Wheatley,Works Connect,worksConnect, Xmbrace,XML ,XenApp,Xen App ..
No comments:
Post a Comment