DEADLINE FRIDAY: Responding to draft CoP RIP Pt.I Ch.II (was RE: ZDNet UK 26/10/2001: "Home Office admits data retention plans")

[Roland Perry]

In message <000201c1612a$74e4ffd0$0300a8c0@aki>, Caspar Bowden 
<cb@fipr.org> writes
>I meant the hypocrisy of collecting data under a SI 2093 S.32 nat.sec.
>exemption, so it can then be accessed for the broad purposes of Pt.1
>Ch.2 nothing to do with nat.sec,

This is probably the most important area to concentrate on at the 
moment. Perhaps the new Retention Code of Practice should specify that 
Section 22(2) purposes are correlated with time limits. So, for example:

CSPs keep all existing logs for 12 months.
Disclosures are accepted for "National Security" up to 12 months
                          for "Serious Crime" for 6 months
                          for the rest, 3 months.

> all the time blithely saying DP
>principles should be adhered to.

Let's not conflate DPA-for-CSPs (almost obsolete standards of 
disclosure) with DPA-for-LEAs (standard for keeping the data safe once 
disclosed) which I recall was one of Brian Gladman's concerns.

-- 
              Roland Perry | tel: +44 1733 207705 | roland@linx.org
Director of Public Policy | fax: +44 1733 207729 | http://www.linx.net
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