OK. This is (hopefully) my final post on the IBTS issues. I may post their response to my queries about why I received a letter and why my data was in New York. I may not. So here we go..
First off, courtesy of a source who enquired about the investigation, the Data Protection Commissioner has finished their investigation and the IBTS seems to have done everything as correct as they could, in the eyes of the DPC with regard to managing risk and tending to the security of the data. The issue of why the data was not anonymised seems to be dealt with on the grounds that the fields with personal data could not be isolated in the log files. The DPC finding was that the data provided was not excessive in the circumstances.
[Update: Here’s a link to the Data Protection Commissioner’s report. ]
This suggests to me that the log files effectively amounted to long strings of text which would have needed to be parsed to extract given name/family name/telephone number/address details, or else the fields in the log tables are named strangely and unintuitively (not as uncommon as you might think) and the IBTS does not have a mapping of the fields to the data that they contain.
In either case, parsing software is not that expensive (in the grand scheme of things) and a wide array of data quality tools provide very powerful parsing capabilities at moderate costs. I think of Informatica’s Data Quality Workbench (a product originally developed in Ireland), Trillium Software’s offerings or the nice tools from Datanomic.
Many of these tools (or others from similar vendors) can also help identify the type of data in fields so that organisations can identify what information they have where in their systems. “Ah, field x_system_operator_label actually has names in it!… now what?”.
If the log files effectively contained totally unintelligible data, one would need to ask what the value of it for testing would be, unless the project involved the parsing of this data in some way to make it ‘useable’? As such, one must assume that there was some inherent structure/pattern to the data that information quality tools would be able to interpret.
Given that according to the DPC the NYBC were selected after a public tender process to provide a data extraction tool this would suggest that there was some structure to the data that could be interpreted. It also (for me) raises the question as to whether any data had been extracted in a structured format from the log files?
Also the “the data is secure because we couldn’t figure out where it was in the file so no-one else will” defence is not the strongest plank to stand on. Using any of the tools described above (or similar ones that exist in the open source space, or can be assembled from tools such as Python or TCL/TK or put together in JAVA) it would be possible to parse out key data from a string of text without a lot of ‘technical’ expertise (Ok, if you are ‘home rolling’ a solution using TCL or Python you’d need to be up to speed on techie things, but not that much). Some context data might be needed (such as a list of possible firstnames and a list of lastnames, but that type of data is relatively easy to put together. Of course, it would need to be considered worth the effort and the laptop itself was probably worth more than irish data would be to a NYC criminal.
The response from the DPC that I’ve seen doesn’t address the question of whether NYBC failed to act in a manner consistent with their duty of care by letting the data out of a controlled environment (it looks like there was a near blind reliance on the security of the encryption). However, that is more a fault of the NYBC than the IBTS… I suspect more attention will be paid to physical control of data issues in future. While the EU model contract arrangements regarding encryption are all well and good, sometimes it serves to exceed the minimum standards set.
The other part of this post relates to the letter template that Fitz kindly offered to put together for visitors here. Fitz lives over at http://tugofwar.spaces.live.com if anyone is interested. I’ve gussied up the text he posted elsewhere on this site into a word doc for download ==> Template Letter.
Fitz invites people to take this letter as a starting point and edit it as they see fit. My suggestion is to edit it to reflect an accurate statement of your situation. For example… if you haven’t received a letter from the IBTS then just jump to the end and request a copy of your personal data from the IBTS (it will cost you a few quid to get it), if you haven’t phoned their help-line don’t mention it in the letter etc…. keep it real to you rather than looking like a totally formulaic letter.
On a lighter note, a friend of mine has received multiple letters from the Road Safety Authority telling him he’s missed his driving test and will now forfeit his fee. Thing is, he passed his test three years ago. Which begs the question (apart from the question of why they are sending him letters now)… why the RSA still has his application details given that data should only be retained for as long as it is required for the stated purpose for which it was collected? And why have the RSA failed to maintain the information accurately (it is wrong in at least one significant way).