Irish Water, Data Protection, and the Cut and Paste Fairy

A few weeks ago I wrote a post here about Irish Water’s Data Protection Policy, which was very poorly written and had all the hallmarks of having been cut and paste from another document (for example references to numbered clauses that were not in the Data Protection Notice).

Today they have advertised on for a Data Protection and Information Security Manager. Ignoring for a moment that this conflates two completely different but related skill sets, the advert on has all the hallmarks of being a cut and paste job from elsewhere. The clues are very obvious to anyone who knows about international data privacy law and practice. Like me.

Take this paragraph for example:

  • Develop and implement Irish Water Information Security and Data Protection policies, processes, procedures and standards based on the existing Ervia framework, legislation and best practice (eg ISO 27000, other industry security standards such as PCI-DSS, NERC/CIP, and FERPA; HIPAA and other privacy/security legislation);

Lots of alphabet soup there that looks very impressive. But what does it mean?

  • PCI-DSS  is a credit card processing data security standard. Scratch that… it is THE credit card processing data security standard.
  • ISO27000 is the benchmark standards family for Information Security.
  • NERC/CIP is a critical infrastructure security standard from the US for electricity networks. It’s used as a reference standard as the EU lacks equivalents at the moment (thanks to Brian Honan for pointing that nugget out)
  • FERPA is not a standard. It is the Family Education Rights and Privacy Act, a US Federal law covering data privacy of student education records. It actually creates rights and duties not unlike the Irish Data Protection Acts, but it applies only to schools that receive funds under an applicable program of the U.S. Department of Education. So, unless Irish Water has a subsidiary teaching creationism in the boonies of Louisiana, it’s not entirely relevant to the point of actually being entirely irrelevant to an EU-based utility company.
  • HIPAA is the Health Insurance Portability and Privacy Act. It is privacy law that applies to certain categories of patient data for patients of US hospitals and healthcare providers and processors of health data such as insurers. In the United States.

Reading through the rest of the job description, the role is weighted heavily towards Information Security professionals. The certifications and skills cited are all very laudable and valid information security certifications. But they are not Data Protection qualifications. Indeed, the only data protection qualification that is specified is an ability to “work the Data Protection Acts”. Work them? I can play them like a pipe-organ!

Given the range of qualifications that exist now for Data Protection practitioners such as the IAPP’s CIPP/E or the Law Society’s Certificate in Data Protection Practice (disclaimer: I helped design the syllabus for that course, lecture on it, and have  set and correct the assignments for it), it’s odd that there is no reference to appropriate Data Protection skills. The question I would pose is what would happen if a Data Protection specialist with experience in ISO27000 implementation, a formal data protection qualification, and experience in data governance applied for the job and wound up shortlisted against someone with a CISSP certification and no practical data protection/data privacy experience, who would get the job?

My reading of the job advert on is that it was cut and paste from somewhere else with minimal review of the content or understanding of what the role of a Data Protection Officer is and how that is related to but different from an Information Security Officer role.

Perhaps it was cut and paste from this advert that appeared almost six months ago It’s for an Information Security and Data Protection Manager in… Irish Water.