Anonymisation: SCL Response to ICO’s Consultation

August 23, 2012

Following a well-attended consultation workshop and input from members of SCL’s Privacy and Data Protection Group, SCL has submitted its response to the Information Commissioner on the ICO’s draft Anonymisation Code of Practice. The workshop was chaired by Hazel Grant, Partner at Bristows and the work on the SCL response has been led by her.

The idea of having a code was welcomed and most reaction to the draft was positive. The response suggest however that the draft was overly focused on public authorities and that it would be easy for private entities to reach the mistaken conclusion that it was not relevant to them.

Other suggestions for improvement include:

·        an extended executive summary was needed

·        the explanation of the ‘process’ of anonymisation should be brought forward to make it easier to find

·        there should be more emphasis on the fact that consent is not always required for anonymisation of data sets to take place

·        more explanation about the requirement for inclusion of details regarding anonymisation and fair processing within the privacy policy was needed – guidance on the ‘triggers’ for this requirement was lacking

·        cloud computing , ignored in the draft, had to be taken into account

·        clarification was needed on ‘penetration testing’.

The full response (4 pages in pdf format) can be downloaded from the panel opposite.

SCL wishes to thank Hazel Grant and all involved in producing the SCL response for their valuable work.