Context
The sharing of personal data while a risk, is key to mapping trends, providing insights to improve services and to help protect against money laundering and fraud. The ICO considers that firms want to use and share data in a safe and legally compliant way. Their Head of Technology Policy, Ali Shah, has set out the priorities in a blogpost, saying the ICO will provide practical guidance and advice on how to assess the appropriate controls.
Key Points
- The latest ICO Data Sharing Code of Practice (https://ico.org.uk/for-organisations/data-sharing-information-hub/) provides organisations with a practical guide on how to share personal data in line with data protection law.
- The ICO recognises that the Code is only a stage in its ongoing work, and confirms that it will continue to provide clarity.
- The ICO will be updating its guidance on anonymisation and pseudonymisation and exploring the role technology might play in enabling safe and lawful data sharing.
Key topics the ICO is considering include:
- The legal, policy and governance issues around the application of anonymisation in the context of data protection law.
- Guidance on pseudonymisation techniques and best practices.
- Accountability and governance requirements in the context of anonymisation and pseudonymisation, including data protection by design and DPIAs.
- Anonymisation and research – how anonymisation and pseudonymisation apply in the context of research.
- Guidance on privacy enhancing technologies (PETs) and their role in safe data sharing.
- Best practice for implementing technological solutions.
- Supporting organisations to choose the right data sharing measures in a number of contexts to demonstrate best practice.
- Gathering insight and feedback from key stakeholders to better understand the real-world challenges and where its guidance can be most effectively targeted.
Next actions
Firms should review the guidance on how to share personal data and consider against existing policy and procedures to ensure these remain appropriate for the activities being undertaken.