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3.16 On 9 May 2018, the same Twitter user followed up that tweet. Ticketmaster responded directly to the tweet saying "this is not a virus, it's the help widget that is found on our home page".
| background | ticketmaster-uk-limited-mpn |
3.17 On the same day, the Twitter user responded to Ticketmaster, stating: "it has an extra line in it submitting information to a website hosted by an External person in the UAE and none of the other inbenta.js files used by other sites have this - this single one has been compromised.
| background | ticketmaster-uk-limited-mpn |
3.18 On or around 10 May 2018, Visa contacted Ticketmaster identifying a number of indicators of compromise and that fraud could be caused by malicious third party content.
| background | ticketmaster-uk-limited-mpn |
3.18.1 Thereafter, Ticketmaster provided Visa's information to the Incident response Team.
| background | ticketmaster-uk-limited-mpn |
3.18.2 However, Ticketmaster's instructions as to the scope of analysis to third party content by the Incident Response Team did not extend at that stage to payment systems within the United Kingdom and EU markets.
| background | ticketmaster-uk-limited-mpn |
3.18.3 Further, Ticketmaster have not evidenced that a link was identified between the information received from Monzo (see above) and that from Visa regarding the Personal Data Breach arising from third party malicious scripts.
| background | ticketmaster-uk-limited-mpn |
3.19. On 11 May 2018, the Incident Response Team analysed Visa's indicators of compromise and failed to identify the malicious code in issue.
| background | ticketmaster-uk-limited-mpn |
3.20. On 31 May 2018, an individual using the Ticketmaster Ireland Website disclosed that their antivirus product had identified Ticketmaster's website as malicious, in particular the reference to the Inbenta tag.
| background | ticketmaster-uk-limited-mpn |
3.21. On 1 June 2018, Ticketmaster internally reported that "the worst- case scenario is that they [Inbenta] are indeed hacked/infected and serving up rogue malicious content to our userbase."
| background | ticketmaster-uk-limited-mpn |
3.22. On 6 June 2018, a Twitter user provided information to Ticketmaster that he was "getting lots of Symantec alerts" about the chat bot in Australia.
| background | ticketmaster-uk-limited-mpn |
3.23. On 6 June 2018, following a telephone call the previous day, Inbenta emailed Ticketmaster to indicate that the identification of Ticketmaster's website as malicious by an antivirus product was erroneous.
| background | ticketmaster-uk-limited-mpn |
3.24. On or around 6 June 2018, Ticketmaster nevertheless instructed the Incident Response Team to expand its investigations to include all Ticketmaster domains.
| background | ticketmaster-uk-limited-mpn |
3.25. On or around 8 June 2018, the Incident Response Team reported that it had scanned 117 terabytes of data to search for malware and found no indication of malware.
| background | ticketmaster-uk-limited-mpn |
3.26. On 22 June 2018 at 8.53pm, Ticketmaster received a notification from Barclaycard regarding around 37,000 instances of known fraud. As set out below, this is the date from which Ticketmaster has stated that it had knowledge of the Personal Data Breach in its personal data breach reports submitted to the Commission... | background | ticketmaster-uk-limited-mpn |
3.27. By an email dated 23 June 2018 at 23.14pm, Ticketmaster attached a formal personal data breach notification.
| background | ticketmaster-uk-limited-mpn |
3.27.1 The attached personal data breach report recorded that the breach was discovered on 22 June 2018 at 8.53pm.
| background | ticketmaster-uk-limited-mpn |
3.27.2 The personal data breach report provided:
"We were Notified by a third party card issuer that it has identified approximately 37,000 credit and debit cards that appear to have been compromised where Ticketmaster UK CPP [meaning "common point of purchase"] was involved. We are not aware of an actual breach or mi... | background | ticketmaster-uk-limited-mpn |
3.27.3 As to the issue of delay in reporting the Personal Data Breach, the personal data breach report provided: "While we have been notified of a possible compromise, because there has been no confirmation of a breach, there has been no delay in reporting."
| background | ticketmaster-uk-limited-mpn |
3.27.4 Under the heading "Taking action", the personal data breach report provided: "We have engaged a and applications
leading forensics firm to conduct a full review of our systems to identify and remediate any potential vulnerabilities related to the potential exposure of the credit and debit cards identified by th... | background | ticketmaster-uk-limited-mpn |
3.28 As around 1pm on 23 June 2018, malicious code on Ticketmaster's website was identified. That malicious code was fully disabled for all territories save for Ticketmaster France and getmein.com.
| background | ticketmaster-uk-limited-mpn |
3.29. As to the malicious code:
| background | ticketmaster-uk-limited-mpn |
3.29.1 Ticketmaster had contracted with Inbenta Technologies Inc ("Inbenta") to provide it with a chat bot for the Ticketmaster websites pursuant to contractual terms requiring software provided by Inbenta to be, amongst other things, free from malware. The chat bot on Ticketmaster's website was designed to interpret u... | background | ticketmaster-uk-limited-mpn |
3.29.2 The JavaScript for the chat bot was hosted on the Inbenta server. However, Ticketmaster decided to include the chat bot on various pages of its website, including the payment page. Ticketmaster said that the chat bot was a critical part of the customer's journey.
| background | ticketmaster-uk-limited-mpn |
3.29.3 It was because of Ticketmaster's business decision to include the chat bot on its payment page that the chat bot was able to unlawfully process the personal data of customers. An attacker directed its attack at the Inbenta servers and inserted malicious code into the JavaScript for the chat bot. The malicious co... | background | ticketmaster-uk-limited-mpn |
3.30 On 4 June 2018, the chat bot was disabled for Ticketmaster France and getmain.com.
| background | ticketmaster-uk-limited-mpn |
3.31 On 25 and 26 June 2018, Ticketmaster provided the Commissioner with verbal updates as to the steps then being taken by Ticketmaster to investigate the Personal Data Breach.
| background | ticketmaster-uk-limited-mpn |
3.32 On 27 June 2018, Ticketmaster publicly disclosed the Personal Data Breach. On the same date, it sent the Commissioner a written update on how the incident was progressing.
| background | ticketmaster-uk-limited-mpn |
3.33 In a statement responding to the Personal Data Breach on or around 27 June 2018, the CEO of Inbenta, told Register UK: "... The Javascript we created specifically for Ticketmaster was used on a payments page, which is not what it was built for. Had we known that script would have been used in that way, we would ha... | background | ticketmaster-uk-limited-mpn |
3.34 It is recognised that Ticketmaster engaged with Inbenta, as outlined at §34- 43 of the First Representations. It is further recognised that Ticketmaster alleges that, in the context of Inbenta having been in breach of its contractual obligations to Ticketmaster to keep its software free from malware, certain respo... | background | ticketmaster-uk-limited-mpn |
3.35 By 28 June 2018, all potentially impacted data subjects were emailed to inform them of the Personal Data Breach.
| background | ticketmaster-uk-limited-mpn |
3.36 On 29 June 2018, Ticketmaster sent the Commissioner an updated personal data breach notification.
| background | ticketmaster-uk-limited-mpn |
3.36.1 The updated personal data breach report stated: "We were notified by a third party card issuer that it has identified approximately 37,000 credit and debit cards that appear to have been compromised where Ticketmaster UK CPP was involved. Following on- going forensic investigations, we have discovered that a mal... | background | ticketmaster-uk-limited-mpn |
3.36.2 The dates of the breach were stated to have been 10 February 2018 to 23 June 2018.
| background | ticketmaster-uk-limited-mpn |
3.36.3 Ticketmaster stated that it had "notified approximately 9.4 million international customers to let them know that they could possibly have been [affected]. All have been sent email notifications."
| background | ticketmaster-uk-limited-mpn |
3.36.4 Further information was provided concerning the action taken by Ticketmaster, which included:
"- An email notification was sent to all customers 27- 28 June 2018 who purchased or attempted to purchase tickets between February 10, 2018 and June 23, 2018. We have notified 9.4 million international customers.
| background | ticketmaster-uk-limited-mpn |
3.37 By a letter dated 29 June 2018, the Commissioner informed Ticketmaster that the case required further investigation. Further information was sought therein.
| background | ticketmaster-uk-limited-mpn |
3.38 By a letter dated 13 July 2018, Ticketmaster responded to the Commissioner's letter dated 29 June 2018.
| background | ticketmaster-uk-limited-mpn |
3.38.1 Ticketmaster explained the operation of the chat bot as follows:
"... 3. Inbenta Technologies provided Ticketmaster with a number of services, including a chatbox service (the "Inbenta Chatbot"). The Inbenta Chatbot provided a customer service interface with Ticketmaster's customers on certain Ticketmaster plat... | background | ticketmaster-uk-limited-mpn |
3.38.2 Ticketmaster stated that, as of 13 July 2018, approximately 500 complaints had been received by it.
| background | ticketmaster-uk-limited-mpn |
3.38.3 Further, Ticketmaster stated: "As part of Ticketmaster's GDPR readiness programme, Ticketmaster invested £2.5 million on an internal privacy portal to deal with data subject rights issues, including complaints."
| background | ticketmaster-uk-limited-mpn |
3.39 By a letter dated 1 October 2018, Ticketmaster provided an "overview of developments in Ticketmaster's investigation into the data security incident that we reported to you on 23 June 2018. " A 28 page schedule accompanied Ticketmaster's letter dated 1 October 2018.
| background | ticketmaster-uk-limited-mpn |
3.39.1 At paragraph 25 of that Schedule, Ticketmaster stated: "... at no point did the Inbenta chatbot software itself load from or
reside within Ticketmaster's systems. Instead, it was at all times served directly to Ticketmaster's customers by Inbenta from Inbenta's servers.e.."
| background | ticketmaster-uk-limited-mpn |
3.39.2 At paragraph 26 of that Schedule, Ticketmaster stated: "... Ticketmaster considers the fact that it did not itself process any data as a result of the deployment of the chatbot and was otherwise constrained in its ability to manage the security controls placed around the software, must inevitably influence the q... | background | ticketmaster-uk-limited-mpn |
3.39.3 At paragraph 66 of that Schedule, Ticketmaster stated: "In conclusion, Ticketmaster readily acknowledges that very unfortunately this attack exposed the personal and payment card data of a number of its customers (though not as many as Ticketmaster had originally understood could have been impacted). However, fo... | background | ticketmaster-uk-limited-mpn |
3.40 By a letter dated 23 November 2018, Ticketmaster provided further information in response to the Commissioner's letter dated 9 November 2018. Ticketmaster stated:
![](https://cdn-mineru.openxlab.org.cn/result/2025-08-26/1adb3da1-34e0-41fd-a9ef-03d69f6f3d40/d724b4634b43a3c8cfff62efddad488fa8607e864a970a537c3c7d1eb... | background | ticketmaster-uk-limited-mpn |
3.41 By a letter dated 29 November 2018, the Commissioner requested further information from Ticketmaster. By a letter dated 7 December 2018, Ticketmaster provided further information in response to the Commissioner's letter dated 29 November 2018. The information so provided included information concerning the chat bo... | background | ticketmaster-uk-limited-mpn |
3.42 By a letter dated 18 December 2018, the Commissioner requested further information from Ticketmaster. By a letter dated 21 January 2019, Ticketmaster provided further information in response to the Commissioner's letter dated 18 December 2018. Ticketmaster stated: "When companies like Ticketmaster contract with th... | background | ticketmaster-uk-limited-mpn |
3.43 The Payment Card Industry Data Security Standard ("PCI- DSS") was the security standard to which all merchants processing payment cards were required to adhere. PCI- DSS Version 3.2 was released in April 2016 and applied until 31 December 2018. PCI- DSS Version 3.2.1 was released May 2018 and is the current versio... | background | ticketmaster-uk-limited-mpn |
3.44 The PCI DSS provided that "the PCI DSS security requirements apply to all system components included in or connected to the cardholder data environment." Systems components included: (i) systems that provided security services (for example, authentication servers), facilitate segmentation (for example, internal fi... | background | ticketmaster-uk-limited-mpn |
3.45 The chat bot in issue, when configured on a payment page, fell within the scope of the term "system components".
| background | ticketmaster-uk-limited-mpn |
3.46 Ticketmaster has provided evidence, for example at §32.3 of its First Representations, that it intended that the chat bot was to be used on its payment page: the chat bot was to "improve the online sales journey, through and including the checkout process—and the payment pages within it".
| background | ticketmaster-uk-limited-mpn |
3.47 In the course of the Information Commissioner's investigation, Ticketmaster provided its Secure Coding Guidelines, which provided at page 3: "all internet- facing applications and applications with a PCI compliance requirement must also go through an application security assessment by the internal LNE Application ... | background | ticketmaster-uk-limited-mpn |
3.48 In those circumstances, despite its repeated contention to the contrary (including at §35 of the Comments) Ticketmaster was bound by the following PCI- DSS requirements concerning the payment card environment, which applied regardless of whether the chat bot was or was not intended or expected to process payment c... | background | ticketmaster-uk-limited-mpn |
3.48.1 PCI DSS requirement 12.2 required Ticketmaster to "implement a risk assessment process that: ... is performed at least annually and upon significant changes to the environment. ... identifies critical assets, threats and vulnerabilities. However, no such risk assessment was performed upon the chat bot being intr... | background | ticketmaster-uk-limited-mpn |
3.48.2 PCI- DSS requirement 12.8.2 required Ticketmaster to "maintain a written agreement that includes an acknowledgement that the service providers are responsible for the security of cardholder data the service providers possess or otherwise store, process or transmit on behalf of the customer, or to the extent that... | background | ticketmaster-uk-limited-mpn |
3.48.3 PCI- DSS requirement 12.8.4 required Ticketmaster to "maintain a program to monitor service providers' PCI DSS compliance status at least annually". However, Ticketmaster did not maintain such a programme.
| background | ticketmaster-uk-limited-mpn |
3.48.4 PCI- DSS requirement 12.4 required Ticketmaster to "Ensure that the security policy and procedures clearly define information security responsibilities for all personnel". However, the contract between Inbenta and Ticketmaster lacked such clear definition of the information security responsibilities in relation ... | background | ticketmaster-uk-limited-mpn |
3.48.5 PCI DSS requirement 12.6 required Ticketmaster to "implement a formal security awareness program to make all
personnel aware of the cardholder data security policy and procedure." It is further provided: "If personnel are not educated about their security responsibilities, security safeguards and processes that... | background | ticketmaster-uk-limited-mpn |
3.49 In its letter of 7 December 2018, Ticketmaster confirmed that it "is not aware of any accreditation held by Inbenta which attest to its compliance with PCI DSS". The following further passages are noted:
| background | ticketmaster-uk-limited-mpn |
3.49.1 "Inbenta has consistently stated to Ticketmaster that their product did not store, process or transmit cardholder data and were thus not subjected to PCI- DSS"
| background | ticketmaster-uk-limited-mpn |
3.49.2 "[The chatbox] was not intended to and did not in fact store, process or transmit cardholder data subject to the Payment Card Information Data Security Standard ("PCI- DSS"). Against this background, Ticketmaster did not query with Inbenta whether PCI- DSS would be applied in respect of the chatbox."12
| background | ticketmaster-uk-limited-mpn |
3.50 The Ticketmaster/Inbenta contract did not include any contractual provisions specifically in relation to the payment environment. Notwithstanding, in its Representations and the Comments, Ticketmaster asserts that it was entitled to rely on Inbenta to provide a safe chat bot on account of Inbenta being "a reputabl... | background | ticketmaster-uk-limited-mpn |
3.51 In its letter of 21 January 2019, Ticketmaster was unable to demonstrate that it had carried out a formal risk assessment of the implementation of the chat bot on its payment page, contrary to (amongst other things) Ticketmaster's own Secure Coding Guidelines.
| background | ticketmaster-uk-limited-mpn |
3.52 By reason of the aforesaid, it was or ought to have been apparent to Ticketmaster that the security of the chat bot was not to a PCI- DSS compliant standard, including by reason of Ticketmaster's own failure to discharge its obligations under the PCI- DSS. Although compliance with the PCI- DSS is not necessarily e... | background | ticketmaster-uk-limited-mpn |
5. Easylife is a controller for the purposes of the GDPR and the DPA, because it determines the purposes and means of processing of personal data (GDPR Article 4(7)).
| legal framework | easylife-limited-mpn-article-5-1-a-20221004 |
6. "Personal data" is defined by Article 4(1) of the GDPR to mean:
"information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification n... | legal framework | easylife-limited-mpn-article-5-1-a-20221004 |
7. "Processing" is defined by Article 4(2) of the GDPR to mean:
"any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by
automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, ... | legal framework | easylife-limited-mpn-article-5-1-a-20221004 |
8. Article 4(4) of the GDPR defines profiling:
"profiling' means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, ... | legal framework | easylife-limited-mpn-article-5-1-a-20221004 |
9. Article 9 GDPR prohibits the processing of "special categories of personal data" unless certain conditions are met. The special categories of personal data subject to Article 9 include "data concerning health or data concerning a natural person's sex life or sexual orientation".
| legal framework | easylife-limited-mpn-article-5-1-a-20221004 |
10. Controllers are subject to various obligations in relation to the processing of personal data, as set out in the GDPR and the DPA. They are obliged by Article 5(2) to adhere to the data processing principles set out in Article 5(1) of the GDPR. Article 5(2) makes clear that the "controller shall be responsible for,... | legal framework | easylife-limited-mpn-article-5-1-a-20221004 |
11. In particular, controllers are required to process personal data in relation
to data subjects lawfully, fairly, and in a transparent manner, as required by Article 5(1)(a) of the GDPR. Article 5(1)(a) ("lawfulness, fairness and transparency") stipulates that:
"Personal data shall be [...] processed lawfully, fair... | legal framework | easylife-limited-mpn-article-5-1-a-20221004 |
12. Article 13 of the GDPR requires information to be provided where personal data are collected from the data subject. Article 13(1)(3) provides:
"Where personal data relating to a data subject are collected from the data subject, the controller shall, at the time when personal data are obtained, provide the data sub... | legal framework | easylife-limited-mpn-article-5-1-a-20221004 |
13. Article 13(3) of the GDPR requires:
"Where the controller intends to further process the personal data for a purpose other than that for which the personal data were collected, the controller shall provide the data subject prior to that further processing with information on that other purpose and with any relevan... | legal framework | easylife-limited-mpn-article-5-1-a-20221004 |
14. Section 1 of Chapter 4 of the GDPR (namely Articles 24-31) addresses the general obligations of controllers and processors. Article 24 sets out the responsibility of controllers for taking appropriate steps to ensure and be able to demonstrate that processing is compatible with the GDPR.
Articles 28- 29 make separ... | legal framework | easylife-limited-mpn-article-5-1-a-20221004 |
15. The Commissioner is the supervisory authority for the UK, as provided for by Article 51 of the GDPR.
| legal framework | easylife-limited-mpn-article-5-1-a-20221004 |
16. By Article 57(1) of the GDPR, it is the Commissioner's task to monitor and enforce the application of the GDPR.
| legal framework | easylife-limited-mpn-article-5-1-a-20221004 |
17. By Article 58(2)(d) of the GDPR the Commissioner has the power to notify controllers of alleged infringements of GDPR. By Article 58(2)(i) he has the power to impose an administrative fine, in accordance with Article 83, in addition to or instead of the other corrective measures referred to in Article 58(2), depend... | legal framework | easylife-limited-mpn-article-5-1-a-20221004 |
18. By Article 83(1), the Commissioner is required to ensure that administrative fines issued in accordance with Article 83 are effective, proportionate, and dissuasive in each individual case. Article 83(2) goes on to provide that:
"When deciding whether to impose an administrative fine and deciding on the amount of ... | legal framework | easylife-limited-mpn-article-5-1-a-20221004 |
19. Article 83(5) GDPR provides, inter alia, that infringements of the obligations imposed by Article 5 GDPR on the controller and processer will, in accordance with Article 83(2) GDPR, be subject to administrative fines of up to €20 million or, in the case of an undertaking, up to $4\%$ of its total worldwide annual... | legal framework | easylife-limited-mpn-article-5-1-a-20221004 |
20. The DPA contains enforcement provisions in Part 6 which are exercisable by the Commissioner². Section 155 of the DPA sets out the matters to which the Commissioner must have regard when deciding whether to
issue a penalty notice and when determining the amount of the penalty and provides that:
"(1) If the Commiss... | legal framework | easylife-limited-mpn-article-5-1-a-20221004 |
21. The failures identified in section 149(2) DPA 2018 are, insofar as relevant here:
"(2) The first type of failure is where a controller or processor has failed, or is failing, to comply with any of the following—
(a) a provision of Chapter II of the GDPR or Chapter 2
of Part 3 or Chapter 2 of Part 4 of this Act (... | legal framework | easylife-limited-mpn-article-5-1-a-20221004 |
22. Schedule 16 includes provisions relevant to the imposition of penalties. Paragraph 2 makes provision for the issuing of notices of intent to impose a penalty, as follows:
"(1) Before giving a person a penalty notice, the Commissioner must, by written notice (a "notice of intent") inform the person that the Commiss... | legal framework | easylife-limited-mpn-article-5-1-a-20221004 |
23. Pursuant to section 160(1) DPA, the Commissioner published his Regulatory Action Policy ("RAP") on 7 November 2018.
| legal framework | easylife-limited-mpn-article-5-1-a-20221004 |
24. The process the Commissioner will follow in deciding the appropriate amount of penalty to be imposed is described in the RAP from page 27 onwards. In particular, the RAP sets out the following five-step process:
a. Step 1. An 'initial element' removing any financial gain from the
breach.
b. Step 2. Adding in an ... | legal framework | easylife-limited-mpn-article-5-1-a-20221004 |
25. This Penalty Notice does not purport to identify exhaustively each and every circumstance and document relevant to the Commissioner's investigation. The circumstances and documents identified below are a proportionate summary.
| background | easylife-limited-mpn-article-5-1-a-20221004 |
26. Easylife is a company based which sells household products through catalogues. The brand was founded in 1992, Easylife was incorporated on 3 September 2004 (at that date "Easylife Group Limited"). Easylife has one active director registered at Companies House, Mr Gregory Grant Caplan, who is the Chief Executive Off... | background | easylife-limited-mpn-article-5-1-a-20221004 |
27. The Information Commissioner's Office ("ICO") conducted due to the potential of direct marketing aimed at exploiting the Covid-19 pandemic, which led to an investigation into (""), a telemarketing company promoting funeral plans during the pandemic. This is turn led the Commissioner to investigate Easylife, because... | background | easylife-limited-mpn-article-5-1-a-20221004 |
28. The Easylife Health telemarketing campaign was conducted by a third-party (""). The "trigger products" consisted of 122 different items sold in the Easylife catalogue. Once an individual had purchased one of the trigger products from Easylife itself, this would trigger a marketing call to the individual by using th... | background | easylife-limited-mpn-article-5-1-a-20221004 |
29. Easylife provided the ICO with marketing scripts selling glucosamine, Cannabidiol, prostaphytol patches and bio-magnetic joint patches. Easylife explained that the majority of the calls made during the relevant period had been targeted at individuals who had been inferred to have arthritis, for instance, a purchase... | background | easylife-limited-mpn-article-5-1-a-20221004 |
30. The script then posed questions about the arthritis, such as how long the individual had had it, its location, the manifestation of symptoms, and its effects on the individual. Then a sales pitch commenced:
"So do you mind if I make a simply suggestion? Many people who suffer with Arthritis will wear Glucosamine J... | background | easylife-limited-mpn-article-5-1-a-20221004 |
31. The Commissioner became concerned that using data about purchasing transactions in order to make inferences about health conditions could constitute profiling, and the inferences made about health conditions could indicate processing of special category data. A sale of glucosamine patches to an individual who had p... | background | easylife-limited-mpn-article-5-1-a-20221004 |
32. The transactional purchase data of Easylife's customers was personal data. When Easylife used that transactional data to influence its decisions on which customers to subject to telemarketing, this constituted profiling. When Easylife used the transactional data to influence its decisions on which products to marke... | background | easylife-limited-mpn-article-5-1-a-20221004 |
33. Easylife relied on its own legitimate interests as the basis for conducting this processing, using a small section of the Easylife privacy policy which stated how personal data would be used:
"How will we use the information we collect about you?
We will do the following with your personal information. Store and ... | background | easylife-limited-mpn-article-5-1-a-20221004 |
37. The data processing agreement between Easylife and covered confidentiality, security, sub-contracting and termination but omitted any reference to the type of data processing which would occur.
| background | easylife-limited-mpn-article-5-1-a-20221004 |
38. One hundred and forty-five thousand, four hundred (145,400) individuals were profiled for inferred health conditions. Zero complaints were made to the ICO, although this was unsurprising to the Commissioner because the contraventions involved invisible processing about which Easylife never informed the individuals,... | background | easylife-limited-mpn-article-5-1-a-20221004 |
8. Tuckers is a controller for the purposes of the GDPR and the DPA, because it determines the purposes and means of the processing of personal data held on its computer systems (GDPR Article 4(7)).
| legal framework | tuckers-mpn-20220228 |
9. 'Personal data' is defined by Article 4(1) of the GDPR to mean: information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification num... | legal framework | tuckers-mpn-20220228 |
10. 'Processing' is defined by Article 4(2) of the GDPR to mean: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, us... | legal framework | tuckers-mpn-20220228 |
11. Controllers are subject to various obligations in relation to the processing of personal data, as set out in the GDPR and the DPA. They are obliged by Article 5(2) to adhere to the data processing principles set out in Article 5(1) of the GDPR.
| legal framework | tuckers-mpn-20220228 |
12. In particular, controllers are required to implement appropriate technical and organisational measures to ensure that their processing of personal data is secure, and to enable them to demonstrate that their processing
is secure. Article 5(1)(f) ("Integrity and Confidentiality") stipulates that:
Personal data sha... | legal framework | tuckers-mpn-20220228 |
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