Helen Dixon has published her first annual report since taking up the position of Data Protection Commissioner (“DPC”). The report highlights what can only be best described as a hectic year for the body. The increased budget and ongoing recruitment drive together with a continued commitment to active regulatory engagement with private and public sector bodies will undoubtedly further strengthen the position of the DPC.

Key Trends

• During 2014, the Office received 960 complaints for investigation. Once again, the largest source of complaints related to data access requests followed closely by complaints related to electronic direct marketing. A new category of complaint emerged in 2014 arising from the EU Court of Justice decision in the Google Spain case. The Office received 32 complaints in relation to unfulfilled internet search delisting requests made against search engines.
• The Office received 2,264 data security breach notifications, an increase of 681 from 2013. The majority of breaches were as a result of human error as opposed to any systemic issues. This highlights the importance of ensuring robust internal organisational (as well as technical) procedures and controls are in place for staff.
• 38 audits and inspections were carried out focusing on technology companies and major public sector bodies. The report indicates that insurance companies and financial sector bodies will be the focus of future scrutiny with regard the use of private investigators.
• The published case studies focus heavily on issues such as marketing offences, excessive data collection and unlawful disclosure or sharing of personal data.
• The Office prosecuted 9 organisations for a total of 162 offences under the Data Protection Acts 1988 and 2003, and the 2011 Privacy and Electronic Communications Regulations.

The annual report is a valuable insight into the work which is undertaken by the Office and the position being adopted by the DPC in her new role. For organisations who are engaged in the processing of personal data it is important to reflect on the findings and apply them as appropriate to your organisation.

Contributed by   Leo Moore & Niamh Gavin

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