Hawktalk

First of all Happy New Year; I hope the recent festive excitement was not too infectious.  Indeed, with the risky policy of letting Omicron rip, let us hope there are not too many ex-data subjects, possibly as a result of the collapse of essential services. I am starting the Year with a real treat; I have been given permission to publish the personal views of Rosemary Jay as submitted to the DCMS consultation “Data: a new direction” (see link at

This blog comprises the response of Amberhawk Training Limited to the DCMS Consultation document “Data: a new direction”  (the “Consultation”).  Amberhawk is a training company established in 2000; its Directors have over 40 years’ experience in training those who are responsible for data protection in an organisation. The response is over 15,000 words and takes the form of 7 blogs, each of which are about 2,300 words long.  They were published during the consultation period which ends tonight and have been

The DCMS Consultation document “Data: a new direction”  (the “Consultation”) proposes to tip the balance between the interests of controllers and the interests of data subject in favour of the controller.  This blog looks at the proposals, not in the context of how beneficial they are for controllers, but rather in the context of how they weaken the privacy protection afforded to data subjects. The weakening provisions being mooted include: Introducing a fee arrangement for subject access which has a

Summary introduction The DCMS propose to change the duties of the Information Commissioner (ICO) in such a way that they decrease the prospect of enforcement on data protection grounds; in this way the changes reduce the protection afforded to data subjects. This prospect arises as the Commissioner will have a duty to consider factors relating to the economy, public safety or the Government’s international agenda prior, for example, to exercising the ICO’s powers of enforcement against a controller. The Secretary

The Government intend to change the accountability arrangements in the UK_GDPR in such a way that it will become harder to hold controllers to account.  In summary, Chapter 2 of the DCMS Consultation document (“Data: a new direction”) makes two main proposals in relation to accountability: to reduce or remove the requirement to undertake DPIAs (A.35 and A.36); to reduce or remove the requirement to have a Data Protection Officer (A.37-A.39); to remove the need to create a register of