Everyday I’m immersed in the challenges faced by organisations and individuals navigating the complex world of Data Protection. Recently, this has been compounded by the developments surrounding the Data Protection and Digital Information Bill, after the government released a keeling schedule for the bill.
Complications and Considerations
Upon reviewing the keeling schedule of the reform bill, I must admit, my initial impression was one of disappointment. The changes proposed by the UK government seem to complicate matters unnecessarily, leading one to wonder if there might be a touch of superiority complex at play. Let’s take a closer look at some of the key amendments and their potential implications.
Data Protection Officer (DPO) to “Senior Responsible Individual”: The bill suggests changing the title of DPO to “Senior Responsible Individual.” This alteration may seem insignificant, but it raises questions about the underlying motivations. Renaming the role could inadvertently dilute the importance and expertise associated with the position, potentially undermining the effectiveness of Data Protection practices within organisations.
Data Protection Impact Assessment (DPIA) to “Assessment of High-Risk Processing”: Similarly, the proposed change from DPIA to “Assessment of High-Risk Processing” introduces unnecessary complexity. The term DPIA is widely recognised and understood within the industry and altering it might create confusion and additional hurdles for compliance.
Adequacy Decision to “Data Protection Test”: The concept of an adequacy decision is vital when it comes to international data transfers. However, the bill suggests replacing it with the term “Data Protection test.” While it’s commendable to emphasise the need for robust Data Protection laws, the bill’s apparent willingness to grant adequacy to any country as long as they have a “materially lower” set of Data Protection laws raises concerns. We must ensure that data transfers do not ..
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