DATA REGULATION
A FINE MESS
GDPR is backed by severe penalties in the event of a breach – a maximum fine of Ð20 million or up to 4 per cent of global turnover, depending on the contravention. A business has to inform the Information Commissioner’s Office (ICO) of a violation within 72 hours. But, as Richard Bristow, director of Tamite Secure IT, points out: “Most companies do not know they have had a data breach for 150 to 180 days on average. They will automatically receive a maximum fine.” He adds: “In the travel business, that’s a big deal because a company that has a turnover of £1 million may only have revenue of £100,000 out of that. The fine will be calculated on the turnover, which could be its profit for the year and put the business in jeopardy.” Meanwhile, the ICO itself has geared up in preparation for GDPR. Speaking at the
Data Protection Practitioners’ Conference in April, UK information commissioner Elizabeth Denham said she had bolstered her team. “We’re expecting more of everything. More breach reports, because the law requires it in high-risk cases. More complaints, because people will be better informed of their rights, and greater engagement as organisations turn to us for advice at the outset. So I am strengthening my team in both number and expertise, and we’re moving the ICO to a place where we can deliver our new responsibilities and obligations to organisations and, most importantly, the public. We are recruiting for a number of new senior roles to give us the capacity, capability and resilience to tackle our developing regulatory brief. We’ve welcomed just over 70 staff from a range of diverse backgrounds and experience, and we have plans to recruit at least another 150 in the next two years.”
DATA CONTROL A data controller owns the data, defines how it is handled by the data proces- sor and with whom it can be shared. Controllers are regulated by law, directly responsible for the data and liable for damage caused by non-compli- ant processing. At first glance, as vendors, TMCs might appear to be data pro- cessors because they are being paid for a defined service and if they have a simple service model where
they are just executing travel bookings on behalf of employee and employer, that could be true. However, Amex GBT’s Chappelle says: “If you are a full service TMC and you are
data, so that you can have somebody’s passport number in one da- tabase, their mobile phone number
in another and address in another. So some- body would not only have to get access to every single database, but also have to have some mechanism for compiling them all from the records,” says ATPI’s Jeffs. “We have split up our data.” ATPI uses a third-party data centre, to
legal obligations or to prevent fraudulent activity, a controller might push back on that request.”
SAFE AND SECURE Data subjects also have the right to request any data an organisation holds on them and to receive it in a portable and accessible format. “It must be user-friendly and acces- sible, viewable as a Word document, pdf or Excel document,” says Garo Mangoyan, IT infrastructure manager for Key Travel. There are several ways in which organisa-
tions can guarantee the security of data they are holding. “Encryption is significant as it ensures that, unless the receiving end holds the right security certificates, even if the data is breached, it is not usable,” says Mangoyan. Pseudo-anonymisation also protects it. “This is a process where you can split up
80 BBT May/June 2018
which access is tightly restricted. “We are accredited to Cyber Essentials; we don’t retain data on individual office sites and if we are aware a laptop or mobile device has been lost, we can lock it out with one instruction,” Jeffs explains. Regular penetration testing is advisable, as carried out by both ATPI and Key Travel. Out-of-compliance emails are a vulnera-
ble area for any business. To protect itself, ATPI no longer accepts credit card numbers by email, but instead sends clients a link that takes them to a website where they key in their details which are applied to the booking and then deleted. At Key Travel, emails are encrypted.
“Agents do not create emails on ordinary workstations but in an automatically encrypted system,” says Mangoyan.
are providing services that mean you have a controller role.” Although GDPR tends to be black and
white about the vendor role, the B2B rela- tionship is not so clear cut.
For more information, go to
ico.org.uk BUYINGBUSINESSTRAVEL.COM
doing a lot of other things with data, making judgement calls about how travel profiles are set up, how systems are being used, how data is collected, processed and shared; if you are providing travel policy compliance, consultancy services, negotiating fares, and you are doing a lot more with the data, you
“Encryption
ensures that even if data is breached, it is not usable”
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