Introduction to Personal Data Protection DCU Risk & Compliance Office October 2015
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1 Personal Data Protection Introduction to Personal Data Protection DCU Risk & Compliance Office October 2015
2 Personal Data Protection - Aims Aims of this presentation 1) Basic definitions 2) 8 principles of data protection 3) DCU s approach to personal data protection 4) DCU staff responsibilities & PDSS ***Tip of the Iceberg***
3 Personal Data Protection - Examples Examples of recent media coverage of DP issues October 2015: US Safe Harbour review by Irish Data Protection Commissioner (DPC). Summer 2015: Irish Minister loses appeal against finding by DPC. Spring 2015: Irish Waters request for customers RSI numbers. 2014: Social Welfare data breach: employee had a long standing arrangement with a Private Investigator for the sharing of clients personal data.
4 Personal Data Protection Why? Why must we protect Personal Data? It s a legal requirement Promotes good information handling practices Protects organisation s reputation Individuals own their personal data, organisations such as DCU, must protect it.
5 Personal Data Protection - Legislation Irish Data Protection Legislation Primary 1) Data Protection Act ) Data Protection Amendment (Act) 2003 Secondary Other assorted EU & Irish Legislation / Regulations ***New Data Protection Regulation in 2016?***
6 Personal Data Protection - Definitions What is Personal Data? Personal data is data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, the possession of the data controller; e.g. CV s, payroll documentation, bank details, CCTV, student data, customer data, medical files, contact data. Definition is deliberately very broad. Data can in either an automated or manual format. Data must be held in a Relevant Filing System.
7 Personal Data Protection - Definitions Sensitive Data Additional category of data which requires extra protection from misuse or disclosure e.g. religion, political opinions, trade union membership, sexual orientation, criminal records, clinical records. Data Subject Individual who is the subject of the personal data. Data Controller Is a person or organisation who controls the contents & use of personal data e.g. DCU. (Excluding employees).
8 Personal Data Protection 8 Principles Personal Data must: 1. Fairly obtained identify yourself & who you may share the data with. 2. Processed only for a specified & lawful purpose state what this is. 3. Not be used or disclosed for any other purpose. (Implication for research activities especially). 4. Kept safe and secure restrict access, train staff, PDSS guidance. (Potential need for Data Processor Agreements).
9 Personal Data Protection 8 Principles 8 Principles Continued Personal Data must be: 5. Accurate & up to date periodically review accuracy. 6. Adequate, relevant & not excessive don t ask for data you do not need. 7. Not retained for longer than is necessary as per the stated purpose i.e. retention policy / safe disposal. 8. Data Subject s Right to Access must provide copy of the data on request.
10 Personal Data Protection DCU s Approach Elements in DCU s approach to Personal Data Protection Policies & Guides Data Protection Policy Data classification Policy Data Handling Guideline Contact with 3 rd Parties Policy Data Protection Officer Advice on all DP related issues e.g. transferring our data to other parties (data processing agreements), staff training and management of data breaches. ISS Services e.g. encryption of devices, s etc. Tailored & unit specific Personal Data Security Schedule (PDSS)
11 Personal Data Protection Your Responsibilities Data Protection Your Responsibilities Be aware of the types of personal data handled by your DCU unit. Be aware of where your unit uses an external party for data processing (must have a DP agreement). Apply controls as set out in the unit PDSS. Where new activities or new modes of operations are planned ensure that the data protection risks inherent in these are managed & addressed at the planning stage. Avoid data breaches!
12 PDSS Example of Template
13 Personal Data Protection Additional Guidance Additional Guidance Contact DCU Data Protection Ext Helpful websites: 1) Irish Data Protection Commissioners Office 2) DCU Data Protection webpage 3) DCU Central Policies Webpage
14 Personal Data Protection - Conclusion Conclusion What we have covered 1) Basic definitions 2) 8 Principles of data protection 3) DCU s approach to personal data protection 4) DCU staff & student responsibilities & PDSS
15 Personal Data Protection Questions?
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