Lotus Connections and the DPAOnce a person is entered into the Connections system they should never be removed. Doing so may invalidate the data's consistency.
One or two commenters on Volker's article mention the Data Protection Act 1998 as a prima facie reason why this is indeed a show stopper.
They are wrong.
The Data Protection Act is frequently cited as an excuse for doing (or not doing) something which, with hindsight, appears foolish.
Couple died after gas was cut off over bill for £140
The decomposed bodies of George Bates, 89, and his wife, Gertrude, 86, were discovered slumped in the lounge of their £500,000 house in southwest London in October.
Six weeks earlier British Gas had cut off their heating and cooking gas supply because the bill had not been paid...
Paul Knapman, the Westminster Coroner, said he would write to Sir Richard Thomas, the Information Commissioner responsible for the Data Protection Act, after British Gas claimed the Act prevented it from telling social services about elderly customers being disconnected.
Notwithstanding this widespread abuse of the Act it is in any case open to broad interpretation - it is up to the party storing the data to assess the need to retain data.
(And, parenthetically, it is worth noting that thus far the DPA is also rarely if ever enforced.)
This apparent DPA issue with Connections is briefly interesting because it seems to illustrate a dilemma - what is the boundary between intellectual property and personal information?
I think it only briefly interesting because a boundary between these two may relatively easily be drawn.
It is standard practice for an employer to retain title to intellectual property created by an employee during the course of his/her employment. This can and often does include things like patents, which always name individuals and often give other context to those names such as job titles or departments. Nobody is seriously suggesting that patent documents should be destroyed after individuals leave a company, because they contain personally identifiable information.
Personal data held by an employer includes items which are, well, personal. These would include things like bank account numbers, held so that salaries and expenses may be paid, and clearly there is no need to retain this type of information after an employee has left a company.
The question raised by Connections is whether a Connections user profile contains personally identifiable information which is materially significant within the meaning of the DPA - and, of course, it might...
But it doesn't have to.
I think a perfectly good case could be made for retaining the name of a former Connections user, his/her last job title and department and the dates of his/her employment. These give context to other material in the Connections repository and are used in exactly the same way as names, departments and titles found in patents.
If a user has chosen to expose more information than this in his/her connections profile then it may be wise to prune this after an employee leaves, although I remain unconvinced that the DPA mandates this.
And, of course, the retention of such a redacted profile document should not enable the former employee in question to gain access to the system. Profiles and access control are distinct features which must be capable of being segregated.
No. If there is a show stopper in Connections it is, for me, somewhat more fundamental even than some apparent conflict with legislative or regulatory frameworks.
I just don't see any compelling feature of Connections that I can't also implement in pure Notes/Domino.
Category: Misc
Technorati: IBM Lotus Connections DPA
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