Data Breach Notification (DBN) policy for In Professional Development

1. Reporting a Data Breach to the ICO

  • In Professional development take the responsibility of collecting and storing personal data extremely seriously. Although there is no legal obligation on us to report breaches of security which result in loss, release or corruption of personal data, we will always work with the ICO and report any serious breaches.

2. What we define as a serious breach

  • Significant potential detriment to data subjects:
    • Detriment includes a high level emotional distress as well as both physical and financial damage.
    • Examples Include; exposure to identity theft through the release of non-public identifiers, e.g. passport number; information about the private aspects of a person’s life becoming known to others, financial circumstances.
    • Significant actual or potential detriment is caused as a result of the breach, whether because of the volume of data, its sensitivity or a combination of the two.
    • Where there is little risk that individuals would suffer significant detriment, for example because a stolen laptop is properly encrypted or the information that is the subject of the breach is publicly-available information, it will be deemed to be a non-serious breach.
  • A high volume of personal data lost / released / corrupted:
    • where a large volume of personal data is concerned and there is a real risk of individuals suffering some harm, In Professional Development will deem this to be a serious breach.
  • Highly sensitive personal data is lost / released / corrupted:
    • A breach of sensitive personal data which could cause a significant risk of individuals suffering substantial detriment, including substantial distress.

3. Reporting a breach

  • Serious breaches will be reported directly to the ICO by; the security breach helpline on 0303 123 1113, electronically to casework@ico.org.uk or by post to ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

4. For further information please contact

In Professional Development limited
FAO Data Controller,
In Professional Development,
164 Bury New Road,
Whitefield, Greater Manchester, M45 6AD
info@inpd.co.uk

ICO
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire SK9 5AF.
casework@ico.org.uk

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