The Information Commissioner has published a new Code of Practice explaining how the DPA applies in an online world, and offering ‘good practice’ advice for the collection and use of personal data through the internet.
The Code covers (among other things) application and payment forms, social networking sites, cookies and other personally-targeted marketing. It considers the difficulties of ‘non-obvious identifiers’ (such as IP addresses linked to devices rather than to individuals), cross-border data transfers by multinational or non-domestic organisations, and the practice of outsourcing the storage of databases to other web-based companies.
With the aid of examples from such contexts, the Code turns established principles into specific recommendations for internet businesses, including: avoid collecting personal data too early in the relationship or transaction with the user; only collect personal as far as is necessary; provide a clear explanation of how users’ personal data will be processed; ensure that employees only have access to customers’ personal data where necessary, and that this access withdrawn as soon as their employment ends.
Certain suggestions will be particularly welcomed by privacy campaigners: alert users to the security risks associated with ‘autocomplete’ forms; give users a simple option of declining to have their personal data stored and of disabling cookies or other trackers of their online behaviour, and make it easy for them to contact the data controller about how their personal data is being used.