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  • The customer conundrum

    I’m a customer of a few on-online services. I have really liked using Tweetdeck for the past few months (hang on… years… eek). The problem is that I’m busy. Nuts busy. I’ve a business, a family, and a strange compulsion to sleep maybe a few minutes or three every day or so.

    I’m a voracious reader and idea gatherer. This is the problem I’m facing now. Tweetdeck/twitter has put a massive pool of people at my disposal who are sticking post-it notes under my nose every few seconds saying “Hey, you might like this. Click through and read it”. And I do. And I get lost in clicks-ville as I wander through related content.

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  • An open letter to Viviane Reding

    Dear Commissioner Reding,

    I’m writing to you as an EU Citizen who is passionate about data, is use, its quality, and its protection. I’m not writing to you as the Managing Director of a company that offers Data Protection training and consulting services, but in the interests of transparency I think it best to disclose that that is my day job.

    I am writing to you about the new Data Protection Regulation. In particular I’m writing to you about the penalties contained in the current draft proposal. Frankly I think they suck. I don’t think they’ll have the effect that you think they will have. I’m basing my opinion on a number of bases:

    1. I have worked in Regulatory Operations in a Regulated industry that you are familar with, telecommunications.
    2. I’m a keen student of human psychology and economics, particularly the psychology and economics of risk and reward.Understanding this “theory of psychology” is important in the world of Information Quality.
    3. I like to observe and learn from other industries and areas of life to see what can be applied to improving quality systems for and the governance of information.
    4. I’m the parent of a toddler. This might not appear immediately relevant but, in the context of Data Protection, my immediate experiences dealing with a stubborn personality in development who is programmed to push boundaries and infuriate me with apparent disregard for the standard of behaviour expected of her all too often find their parallels in the management teams and staff of organisations I’ve worked with.

    Taking these elements together I am afraid that 5% of Global turnover will not work as a penalty. It’s a great soundbite but will, in practical terms, amount to little more. There are a few reasons for this.

    (more…)

  • Newspaper Licensing Ireland–a revisit

    So, late last night I wrote a post about NLI and their link license fee nonsense.

    In that post I decided to focus on the non-compliant behaviour of an organisation setting itself out as being the arbiters of compliance with copyright when it came to the data protection/privacy compliance obligations that they appear to either be unaware of or consciously ignorant of (I presume the latter).

    I clearly stated that I wasn’t going to talk about the economic impact of inbound links to websites from the point of view of driving search engine relevance, getting sites onto the first page of Google, and generally providing a basis for establishing valuation models for on-line advertising.

    It’s not my area of expertise, so I thought it best not to say anything.

    But today I searched for “Newspaper Licensing Ireland” in Google.

    I was pleasantly surprised to see that, apart from content by or directly about Newspaper Licensing Ireland, there were articles by Broadsheet.ie, McGarrSolicitors, and your humble scribe.

    On page 1 of Google. In the top 6 things returned for that search string. In less than 24 hours.

    What made this happen? Links. Lots of loverly links being spread through websites and social media networks like, as I described them last night, the “footnotes on the Internet”.

    This is what helps drive traffic to websites, making them more valuable pieces of virtual real estate within which to place advertising.

    Charging people a fee to put up a sign post to your shop makes no economic sense in the bricks and mortar world. It makes even less sense in online.

    After all, links are more properly called “Universal Resource Locators” (URLs). And in this way they are exactly the same as sign posts. They tell people, uniquely, where to find a particular resource. Just like a footnote in book.

    Will NLI start charging license fees for those as well? If so, I’m fudged completely as my last two books have LOADS of footnotes in them.

  • Newspaper Licensing Ireland–a return

    The last post was a little long and analytical. Having reread the great post on McGarrSolicitors.ie I thought I’d reframe my Data Protection take on this in terms that might be more familiar.

    Personal Data is being processed via your website without an appropriate Privacy Statement and without any communication of the purposes for that processing. Furthermore, the failure to have such a privacy statement on your site which references the use of Google Analytics is a breach of Section 8 of the terms and conditions that apply to Google Analytics. Failure to obtain consent for the use of the cookies written by Google for the purposes of Google Analytics is a breach of SI336.

    You are breaking the law; you risk exposing your company to investigation and prosecution, with financial penalties and brand damage ensuing. Processing personal data without it being obtained fairly for a lawful purpose, and writing 3rd party cookies without consent is illegal and breaches a fundamental Human Right in the European Union.

    What do you think?

    I may be over egging it a little. I need a cup of tea now and a good sit down.

  • Newspaper Licensing Ireland– some thoughts

    This post is about the website of Newspaper Licensing Ireland, who have recently written to a non-profit organisation whose aims I wholeheartedly support, seeking license fees for linking to newspaper content published on the internet by the newspaper publishers. McGarr Solicitors, who are acting for Women’s Aid, have published a detailed analysis of the situation and the questions raised on their website, which I link to in the confidence that the McGarrs won’t come looking for a pound of flesh in return.Sticky buns perhaps, but nothing worse.

    I will ignore the fact that this action seems to be in ignorance of the way the Internet works, particularly with regard to search engine optimisation and page ranking where relevance and significance of content, and hence it’s positioning in Google searches and the value of the real-estate for on-line advertising purposes. I’ll ignore how the use of links simply tells people to “look over here – I found this interesting, so you might to”. I’ll ignore the fact that links are effectively the footnotes on the Interweb that tell people where your source was for a thing. 

    (But if you do want to actually understand this aspect, the Wikipedia entry on Search Engine Optimisation has a reference to the Google PageRank algorithm and how it works (at a high level). And Dr. Cathal Gurrin in Dublin City University did his Doctoral thesis on the topic.And I’m sure someone somewhere has done an economic analysis of link density [the number of inbound links to a site] but I can’t be bothered to look for it tonight.)

    What I will talk about here is the fact that, when I went to the NewsPaper Licensing Ireland site (which I won’t link to… just in case) to see what the potential cost to an SME with 0-10 employees would be. I still don’t know the answer.

    I’d expected a form that would take certain inputs and churn them around to spit out a ball park figure. I’d expected to see something that would relate the license cost to, for example, the average hits or distinct site visits on the SME company site per month (to make the cost meaningful as those stats are the foot fall of the Web).

    What I didn’t expect was to be asked for a contact name and the name of the company on that form. Company name I’m not to concerned about. But the contact name…

    …that’s personal data. Therefore under s2 of the Data Protection Acts it must be obtained for specified and lawful purpose and must be fairly obtained. So I went looking for a Privacy Statement (there was none). So I turned on my cookie checkers to see what was being written by the site to my device wot is connected to a public communications network (and therefore would be a cookie within the meaning of SI336 and as such would require consent unless necessary for the service I’m trying to avail of).

    My tools revealed that NLI are using Google Analytics on their site. In a manner which is in breach of the Terms and Conditions of use for Google Analytics which state very clearly in Section 8:

    8. PRIVACY

    8.1 You will not associate (or permit any third party to associate) any data gathered from Your Website(s) (or such third parties’ website(s)) with any personally identifying information from any source as part of Your use (or such third parties’ use) of the Service. You will comply with all applicable data protection and privacy laws relating to Your use of the Service and the collection of information from visitors to Your websites. You will have in place in a prominent position on your Website (and will comply with) an appropriate privacy policy. You will also use reasonable endeavours to bring to the attention of website users a statement which in all material respects is as follows:

    “This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”).  Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States . Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.  Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.  You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.  By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.”

    The emphasis in bold is mine. What Google requires is for people using GA to put in place a Privacy Statement but that that Privacy statement needs to clearly detail the use of Google Analytics, the fact of data transfer to the US, the purposes to which the data will be used etc.

    NLI have no such Privacy statement, and no such text, so no mechanism to confirm my consent to the cookies that are being written by Google Analytics.

    So, the site is operating in breach of SI336 and Google’s terms and conditions, and is effectively breaching contractual conditions governing the use of Google’s services and the fundamental right to Personal Data Privacy as enshrined in Article 16 of the Lisbon Treaty.

    All of which I’d never have considered looking at at all if they weren’t sending threatening letters to a charity that exists to help and protect women experiencing domestic violence.

  • Culture of Compliance

    So, Phil Hogan believes that the vast majority of people in Ireland want to be compliant with legislation, specifically the Household Charge. Perhaps a first step to ensuring that compliance would be for the Minister to ensure that the Household Charge is being implemented in a manner that is compliant with the Data Protection Acts. That would have meant

    1. Early consultation with the Data Protection Commissioner to identify and mitigate Data Protection risks in the Household Charge legislation
    2. Early consultation with the Data Protection Commissioner to ensure that appropriate mechanisms for data sharing were given effective legislative support within the Household Charge legislation
    3. Ensuring clarity about the current and proposed future uses for the (significant) amount of data which is being gathered as part of the registration process
    4. Ensuring that the use of PPS Numbers as part of the registration process was clearly and demonstrably being approached in a manner that complies with the requirements of the Social Welfare Consolidation Act 2005
    5. Ensuring clarity about who the Data Controller is for the Household Charge scheme (it appears to be de facto the Department at this point, despite the text on the Privacy Statement on their website).
    6. Communicating early and often with the public about the charge, its legal basis, the purposes to which data that is being collected will be put to etc. etc.

    Instead we have a Minister announcing on national radio that the Government is backing him in reviewing all relevant legislation, including the Data Protection Acts, to allow the Household Charge to be collected. Thankfully the Data Protection Commissioner’s rebuttal of that utter nonsense has been getting more air time since, but I thought it might be worth a quick examination of why the Minister’s comments were total poppycock.

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  • Chuggers (and why I’m not a fan of them)

    Imagine I walked up to you on the street with my arm outstretched to shake your hand and making direct eye contact with you and smiling. Imagine if the next thing I said or did was to ask you to give me

    • Your name
    • Your credit card or bank details
    • Your mobile phone number
    • Your home address
    • Your email address
    • A copy of your signature

    and a range of other personal data. Which I wrote down on a piece of paper and stuck in my bag before thanking you and walking off.

    Chances are I wouldn’t get very far in gathering that information. Your natural sense of risk would (or should) kick in. Chances are you’d call the police on me.

    But imagine that scenario again with one small change. I’m wearing a polyester jacket with the logo of a charity on it and I’ve got an ID badge hung around my neck and a backpack. What would you do then? Hey, I’m collecting for a charity.

    I am a charitable person. I like to support good causes and I like to contribute as much as I can when ever I can to such causes. But I’d say no to me because  of my personal sense of Information risk.

    Others base their dislike of Chuggers (Charity Muggers) on the methods that some use to get people to sign up, methods which are often the result of the commission or quota based systems that some of these people work under (and I’ve content elsewhere about why quotas are a BAD idea in the delivery of quality service). Of course, these are methods which charities who use this means of fundraising disavow all knowledge of and disown completely, but which I have witnessed.

    My avoidance of chuggers is based simply on good Information Security practice. I don’t like the idea of my data being in a bag around someone’s neck or a plastic zip-lock folder, in a public place.  From a Data Protection of view I’d rather not have to have a real-world test of the compliance of the organisations that run these collection methods with things like the Data Security Breach Code of Practice or the requirement under S2 of the Data Protection Acts to take reasonable and appropriate steps to ensure the security of personal data. Particularly not with my data. The data that is obtained by Chuggers is Personal Data within the meaning of the legislation as it is data that has been obtained with the intention of processing it electronically or of filing it in a relevant filing system, ergo it needs to be treated with care.

    I’ve advised clients in the non-profit sector of the potential for brand damage arising from something as simple as one of their Chuggers being mugged and their bag being stolen… or to put it another way: the temporary storage location of an array of personal data. I’m not saying don’t use the method. What I’m saying is your controls need to be very tight.

    Among the controls that need to be in place is appropriate training for staff on Data Protection. I’m not sure if such training is happening as many of the techniques I’ve seen or heard of being used to get people to stop could actually be construed as being contrary to the requirement for consent to processing of data to be freely given. That said, a volunteer for one charity came on a Data Protection course I taught a few years back and they stopped using chuggers afterwards.

    If the UK experience is anything to go by, my risk aversion is justified. The ICO there has investigated charities for loss of data. It is inevitable that similar will happen here, if it hasn’t already (but if it has I can’t find a reference to it on the Data Protection Commissioner’s website). The root cause in the UK case I link to was a lack of training and awareness that lead to a loss of data.

    So how should your chugger experience go? Well, first of all you should know what happens to all this information you have just given them. The chugger is meant to either give you a data protection statement to read or explain to you who will be processing (using) your information, who they will share it with and also give you the chance to say you do not want them to pass it on to anyone else. They should also make sure that once you have signed the form to agree to what you want to do, the form is kept safe and secure, rather than what normally happens where they add it to some others in a plastic folder or clipboard they are holding.

    My advice to anyone accosted by a chugger is: if you can’t get away, ask politely for a copy of the charity’s form for you to fill in at your leisure. If they don’t give it to you take their name from their ID badge and report them to their Charity and if the Charity doesn’t take it seriously report it to the Data Protection Commissioner. (If they don’t have an ID badge, assume they are not representing a charity and you’re about to be mugged – react accordingly).

    My advice to any Chugger who is careless with their folder or is mugged for their bag… notify your Charity immediately. The Charity should notify the Gardaí as well and make sure they know that there was personal and financial data stolen/mislaid. The charity should also notify the Data Protection Commissioner. As the paper work will not have been processed you won’t be able to notify the Data Subjects directly (as is required under the Code of Practice) so they will likely have to put out a public statement about the loss of data to alert people who have given their details to the risk of identity theft.

    Personally, I make my donations either on-line (and I look for PCI compliant payment processors and HTTPS security on the donation page) or over the phone. I have never and will never donate to a charity by means of a chugger, and when faced with a choice I will opt for a charity that doesn’t use them.

  • Correction from Irish Examiner re: Vatican Closure

    After some toing and froing and an email trail that included quotes from the Chairman of TCH (the parent company of the Irish Examiner) at #mediv2012 I finally got clarification from the editor of the Irish Examiner of their Vatican Embassy story (soon to be corrected on-line), which I first blogged about on the 19th of January.

    At my suggestion, Dolan O’Hagan (the editor) provided the text of the clarification (which ran in the print edition two weeks ago but never made it online until today) for me to post here to close the loop so to speak. I’ve made the font bigger for the quote so that the text can be more clearly seen.

    In an article published on January 16 headlined "Public decries closure of embassy to the Vatican" it was stated in the opening paragraph that  the embassy closure "was met with overwhelming opposition from the public with over 93% criticising the move".
    The Irish Examiner would like to clarify that it was, in fact, 93% of those who had written to the Dept of Foreign Affairs in the immediate aftermath of the announcement who had voiced opposition to the move – a fact reflected later in the story but not in the opening paragraph due to a copy review error.

    While I differ slightly on the claim that the latter part of the story reflected accurately the level of actual uproar about the Vatican closure (I feel that the section in question required some close reading to understand the actual sample size involved which the 93% referred to), I welcome the statement from the Irish Examiner that does go a substantial way to clarifying the issue. I look forward to seeing the promised amendments and clarifications in the on-line edition soon, and once that happens I’ll be gladly closing my complaint with the Press Ombudsman.

    Of course, there is an important lesson for anyone producing information that is distributed through multiple outlets – an error may need to be corrected in a timely fashion in multiple locations. As such you will need to know when and where that information was disseminated and what control you have over getting the facts corrected.

    (Indeed, under the Data Protection Acts if a Data Controller is informed of an inaccuracy in personal data they have to inform anyone they shared that data with in the previous 12 months who in turn must notify anyone they shared it with etc. Frankly it’s turtles all the way down until the data universe is as correct as it can be made).

    Now my hope is that, with the correction on the part of the Irish Examiner, the other publications which picked up the 93% rallying cry will in turn correct their copy so that it reflects the reality of the situation, not hyperbole caused by an error in review.

  • SOPA, Irish political debate, and keyboard warriors

    I work in a knowledge-driven sector (consulting and training). I have written two publications that have ISBN numbers, which makes them books I suppose. They were each over 100 A4 pages long. I’ve written hundreds of blog posts and articles over the years and have a large external hard drive filled with every presentation I’ve given in my topic area (Information Quality, Data Protection, Data Governance) over the past number of years.

    In my professional capacity I am a member of a number of professional associations and have a number of professional certifications, all of which have an ethics element which, amongst other things, requires me to respect copyright and to give credit to the works of others when I am using them.

    As a presenter I’ve experienced flying in economy class to far flung places to see the person in front of me on the agenda ripping off the presentation I was just about to give because he’d come into possession of an earlier version of my slides from a previous event (in that case I just changed my presentation and explained to the audience why while the guy sat in the front row looking for an emergency exit – perhaps repeatedly saying how much I agreed with his points might have been laying it on to thick).

    But the SI that is about to be signed into law is just nuts, aimed solely in my opinion at propping up a dying business model in which KPI indicators that were perfectly valid 10 years ago are falling and rather than pull the levers and turn the knobs in their own business model and evolve, an industry lobby is seeking to pull levers and turn knobs in society as a whole and create a time machine that puts the smoke of 20 years of technology evolution back in the bottle.

    I teach and consult on-site with clients. I have also been published in dead-tree formats. e-learning and on-line tutorials and coaching, blogs, internet based publications, e-books all challenge that business model. So is my response to lobby hard for legislation and burn cash in litigation to reverse the universe? No. I’m not a moron. I embrace the opportunities for new business models that the Web provides. I look to build a Platform Business (to borrow from my friend Phil Simon) and I seek to develop new ways to distribute and monetise my services and my knowledge. (So expect to see some things developing from my business over the next few months)

    That the Irish Music Industry has strong armed the Government into rushing bad law in in a bad way is irksome in the extreme. That a mortally wounded industry has been able to bully (and yes, I do feel that the approach taken amounts to bullying) a Government into bringing in legislation of a kind that a vibrant and growing industry sector (that would be the Interwebs and Cloud) had lobbied and campaigned against successfully in the US only a few weeks ago galls me. That it is happening when the legal position in Europe has evolved and the clear message from TWO EU Commissioners (including the Vice-President of the Commission) is that Internet Blocking is not an option in Europe (ergo the Commission would be unlikely to penalise Ireland for not having it in place) just sickens me.

    But what really sticks in my craw is the pantomime of a Dail debate that we saw last night which makes a mockery of parliamentary democracy in this country. A debate where a perfectly workable alternative piece of legislation that achieves largely the same objectives while balancing the needs and interests of the ISPs (who were NOT consulted or engaged with when the original SI was being prepared) was basically ignored.

    The debate highlighted how out of touch with their electorate the Government is. Dismissing people who WRITE to you as “key board warriors” is insulting and disingenuous to say the least. I am a keyboard warrior and proud of it. I use my keyboard to effect change in organisations, educate and inform. It is my TOOL. Just as my grandfathers’ tools were pens and typewriters (for one) and trowels and plaster (for the other). My keyboard (and my website) is my own personal printing press with a scope, scale, and reach that Guttenberg could never have imagined.

    Bad law, introduced badly, by people who don’t grasp the basics of what they are seeking to regulate and control, with an arrogant dismissiveness of comment and debate from the political class (with notable exceptions) has the makings of a total trainwreck.

    As an aside, when I first raised concerns last year about the Fine Gael website I was dismissed  as being “only a blogger”. This keyboard warrior was right, so the track record of arrogant dismissiveness from Government parties has not been good on things internet related.

    So I contacted my Government party TDs by phone this morning to express my dissatisfaction. If my keyboard won’t be listened to then I’d better start using my voice.

  • While we’re all fired up about protecting rights..

    Hey you #stopsopaireland people, I’ve got a favour to ask. It’s not a big one. It will take you 30 seconds to do but it may help to make your life a little better

    The 30 seconds kicks in as soon as you’ve finished reading this post.

    The discussion around #stopsopaireland has focussed on the impact that internet blocking would have on fundamental rights of freedom of expression, and the EU legislative and policy frameworks and case law that exist to support that right and ensure it is protected in a balanced way.

    There is another right that is important. The right to Privacy. In particular the right to Personal Data Privacy which is set out in Article 16 of the Lisbon Treaty. It is this Article that provides the basis for the EU’s Data Protection regime, changes to which were announced on Wednesday. Those changes will take a number of years to come into affect, assuming they are not bastardised and watered down beyond all recognition by national parliaments or the European Parliament responding to lobby groups.

    But a functioning Data Protection framework is in existence day and it is policed in Ireland by the Data Protection Commissioner. Already this year they have engaged with the Dept of the Environment regarding the Household Charge database and with Dublin City Council regarding the transfer of personal data from Dublin City Council to a private company. And let’s not forget their audit of Facebook last year. And that’s just the high profile stuff that gets in the media. In my professional context I’m aware of the significant number of complaints they help people with each year as they strive to promote compliance with the Data Protection Acts in an increasingly complex information management environment and a financial culture where organisations and governments are trying to to less with more and often cutting the wrong corners in the process.

    The Office of the Data Protection Commissioner serves the individual citizen, helping them with advice regarding their rights and acting to investigate and prosecute breaches of those rights. They also serve the Organisation (be that a Government department, a large multi-national, a local football team, or a student company selling jumpers on-line) providing education and advice (when asked) as to what steps should be taken to ensure the right balance is struck between the goals of the organisation and the rights of the individual. They don’t deal with just one sector of the economy. Anywhere personal data is being processed they have a role to play.

    Saturday 28th January is World Data Privacy Day. It is one day in the year where Data Privacy is celebrated. Companies and regulators around the world have planned activities and events to celebrate the day (see here and here), but in Ireland it seems to be just another Saturday. Some of you might say that the Data Protection Commissioner should have lead the charge on this but, to be frank, they are under resourced in terms of numbers and budget and need to prioritise their efforts and energies to dealing with the actual and alleged breaches of people’s rights that come through their inbox every day.

    So, to celebrate World Data Privacy Day 2012 I’m asking you to write an email to your TD, Minister, or other elected official asking them to comment, tweet, or in some other way make public

    1. Their support for the principles set out in the Data Protection Acts and the proposed revised EU Regulation on Data Protection
    2. Their commitment to ensuring the Office of the Data Protection Commissioner is properly funded and resourced to allow it to execute its duties under the Acts and the Lisbon Treaty in an effective and truly independent manner.
    3. What one thing they will do by January 2013 to improve their personal knowledge of the Data Protection regulations.

    I’ve even put sample text below so you can just cut and paste it. You can use the great contact form at Contact.ie to bulk contact your elected representatives (while you are there, why not donate to support the site), or you ca nmake the message personal and send it yourself from your own computer/phone/device/smoke ring maker. Heck, if you want to phone them or tweet them directly about this fire ahead.

    +++ email text

    Dear Sir/Madam

    I write to you on the occasion of World Data Privacy Day, which is being celebrated globally on Saturday the 28th of January (mark your diary, it’s the same day next year).

    Personal rights, particularly personal rights in relation to information and personal data, have been in the media a lot this past month. Much of the coverage could have been avoided had proper attention been paid to the requirements and obligations under the Data Protection Acts 1988 and 2003 which apply equally across a wide range of industry sectors, including Government

    To celebrate World Privacy Day I would ask you to consider issuing a statement either by traditional press release, a blog post, or a tweet, that will tell your electorate where you stand on the following questions:

    1. Do you support the principles set out int he Data Protection Acts and in the proposed revised Regulation on Data Protection announced this past week by Vice President of the European Commission Viviane Reding?
    2. Are you committed to  ensuring the Office of the Data Protection Commissioner is properly funded and resourced to allow it to execute its duties under the Acts and the Lisbon Treaty in an effective and truly independent manner, as is required under EU Directive and the Lisbon Treaty?
    3. What one thing will you do by this time next year to improve your personal knowledge of the Data Protection regulations.

    Of these three questions, the second is one I feel is important.  Personal data is the currency of the new economy and it is a valuable commodity. The Regulator for the Personal Data Industry is the Data Protection Commisioner. One of the key lessons of the Financial crisis is that for a Regulator to be effective they must be correctly resourced and independent of Government or industry influences.

    I appreciate your time on this and look forward to seeing your press release, blog post, or tweet expressing your support for #DataPrivacyDay, the principles of Data Protection, and the office and role of the Data Protection Commissioner.

    ====ends===

    If you get responses please post a comment below so I can see what uptake (if any) there has been from our political classes.