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:
- I have worked in Regulatory Operations in a Regulated industry that you are familar with, telecommunications.
- 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.
- 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.
- 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.