December 12, 2012 | Peter Bradwell

How the Home Office let their Minister down

A week ago the Home Secretary said that anybody opposed to the draft Communications Data Bill was 'putting politics before lives'. Yesterday the Joint Committee on the draft Communications Data Bill, which was set up to scrutinise the proposals, published its damning report that concluded the draft Bill pays "insufficient attention to the duty to respect the right to privacy, and goes further than it need or should."

The report delivers a pretty withering verdict on the Home Office team responsible for the draft Bill. It calls their evidence 'fanciful and misleading', for example. It's clear that in the way the policy was developed and explained, the Home Office have badly let down the politicians, from the Home Secretary to the Deputy Prime Minister.

It has pushed the former to defend, in good faith but questionable language, what the Committee concluded are ill considered and unsupported proposals. And it has created an unnecessary fissure in the Coalition. All this because of the insular, overambitious and secretive process the Home Office insisted on running.

Below is a non-exhaustive set of examples of the Committee's findings that demonstrate three key Home Office failings: a failure to consult; a failure to properly define the problem; and a failure to adequately explain and support their proposals with good evidence. It is a pretty damning catalogue of issues.

This is why we now need a fundamental review of surveillance law. The Home Office's Snoopers' Charter is a fudge of a solution to the problems of law enforcement in the digital age. They've aptly demonstrated that they should not be entrusted with the review. 

1. The costs and benefits estimates were not robust:

On the supposed financial benefits:

"267. It may be that, for some purposes, it is useful to be able to ascribe a monetary value to a life saved. We fail to understand what relevance this can have in the impact assessment for a draft Bill. The figures are used to attempt to show that the taxpayer, by spending £1.8 billion over ten years, will recoup perhaps three times that amount, when this is not the case. To suggest that these estimates can be used to calculate a net benefit from enactment of the draft Bill at between £3.2 and £4.4 billion is simply fanciful and misleading.

268. The use of figures in this way points to a further absurdity. We are asked to believe that access to a further 10% of communications data over and above the 75% already available would save perhaps a further 150 lives a year. Logically, it should follow that the communications data currently available is saving around 1,000 lives a year, but the Home Secretary told us that the figure was “1,000 to 2,000 lives being saved” over the 10 year period. None of our witnesses could provide specific evidence of significant numbers of lives saved to date.

269. The figure for estimated benefits is even less reliable than that for costs, and the estimated net benefit figure is fanciful and misleading. It ought not to be used to influence Parliament in deciding on the relative advantages and disadvantages of this legislation. Whatever the benefits of the Bill, they are unlikely to be financial." (page 71)

On costs:

"257. …in his subsequent evidence Charles Farr told us that, on the basis of the regular discussions the Home Office had with the UK CSPs on their costs in implementing the RIPA arrangements, “we know in quite a high level of detail what those costs comprise [and] we have already formed the basis of our calculations about the costs that the CSPs may incur in future. We have added in considerable optimism bias on top of that. I would not want you to conclude that we have plucked these figures out of thin air. They are based on existing costs which we have already established with the providers. It is still our view ... that these figures accurately represent the likely cost going out to 2020.” The business case was being “refreshed”, but he did not anticipate that it would come up with a figure higher than £1.8 billion.

258. Mr Farr repeated that this figure “builds in quite a lot of optimism bias”. For Microsoft, Mr Collins had told us: “... the costs will increase. Even if we gave you a figure now, I would be willing to bet money that in 10 years’ time that cost will have multiplied grotesquely.” The figure he was referring to was the cost to CSPs. We think he would be betting on a certainty. Future developments are entirely unpredictable. It is impossible to foresee what new communications providers or forms of communication may emerge, perhaps from overseas, that will suddenly become a significant player and incur recoverable costs. We expect the overall cost to the taxpayer over the next decade to exceed £1.8 billion by a considerable margin." (pages. 68 and 69)

"262. We are concerned that the Home Office’s cost estimates are not robust. They were prepared without consultation with the telecommunications industry on which they largely depend, and they project forward 10 years to a time where the communications landscape may be very different. Given successive governments’ poor records of bringing IT projects in on budget, and the general lack of detail about how the powers under the Bill will be used, there is a reasonable fear that this legislation will cost considerably more than the current estimates." (p. 70)


2. They did not define the problem properly:

"36. We are of the strong view that the 25% data gap is an unhelpful and potentially misleading figure. There has not been a 25% degradation in the overall quantity of communications data available; in fact quite the opposite." (p 16).

"40. It was not long into our inquiry that we began to question the utility of the 25% figure and we asked the Home Office to identify what specific data types are currently missing. After some months the Government agreed to tell us on a confidential basis that there were three main data types that they hoped the legislation would be used to make available. At that point they argued that these data types could not be publicly identified without risking exposing loop holes to criminals. This need for secrecy was one of the drivers for the very broad drafting of clause 1." (p. 18)

"288. The Home Office has argued that there is a case for keeping clause 1 wide because there may be other data types that emerge from time to time which will be important to law enforcement but will not be routinely retained by CSPs for business purposes. We do not accept that this is a good reason to grant the Secretary of State such wide powers now. We do not think that Parliament should grant powers that are required only on the precautionary principle. There should be a current and pressing need for them." (p 75)

3. They did not adequately consult with the Information Commissioner:

"206. We found it hard to understand how additional duties could be imposed on the Information Commissioner without first consulting him, asking him what duties he thought sensible and feasible, whether he would be able to comply with them, and what additional resources he might need to do so. We put this to Home Office officials on 24 October, and Charles Farr replied:

“The Information Commissioner had seen the draft clauses of the Bill which affected him in advance. He had a meeting with the Minister; he had three hours with Richard going through the detail of the legislation."

207. As in the case of the consultation with the CSPs, which we discussed in the preceding chapter, this evidence appeared to contradict what the Information Commissioner had told us. Subsequently however the Home Office agreed that the reference to a “meeting” with the Minister was an error; this was in fact a phone call following the publication of the draft Bill. As to the draft clauses affecting him, the Information Commissioner has told us in a letter of 6 November that he asked on 23 May to see them in advance of a meeting on 31 May; his request was refused, and it was only at that meeting that he was given a copy of those clauses. He was sent a copy of the draft Bill the day before it was published." (p. 55)

"What is clear to us is that the Government has chosen to include in a draft Bill which had a very long gestation a clause imposing on the Information Commissioner additional duties, and that prior to the publication of the Bill there was no consultation with him about those duties, about the information he would need to carry them out, about whether it would in fact be possible for him to undertake those duties, about whether he would need further powers, and about what extra resources he might need. If they hoped that, by inserting this clause in this way, they would be providing an additional safeguard which might allay concerns about the draft Bill, we can only say that they were mistaken." (p. 55 / 56)

4. Failure to consult with CSPs:

"53. What is absolutely clear to us is that the regular meetings with EE and the other major CSPs would have been an unrivalled opportunity for the Home Office to discuss with them the evolving policy and content of the Bill, and to seek their input on the many matters where their technical and general expertise could have made a valuable contribution; and that this opportunity was not taken. The draft Bill is the poorer for it." (p. 22)

"49. ...On behalf of Facebook, Simon Milner said categorically: “We had no dialogue with the Home Office before the Bill was published...we were never asked [for input] and we never provided it.” Similarly, Colin Crowell for Twitter: “We had one conversation with the Home Office about two and a half weeks ago.51 So we, too, were contacted after the Bill had been published and had one phone conversation with them about it.” (p. 20 / 21)

"51. In the case of the overseas providers, Mr Farr told us that he had read their evidence “with a lot of interest”; what he told us was almost the opposite of what they said." (p. 21)

"55. Mr Farr told us: “Parliament and others had a right to see the legislation before we discussed it in detail with overseas providers.” We do not accept this. Parliament has a right to see, on its introduction, a Bill which seeks to implement as fully and clearly as possible the Government’s policy, however controversial that policy may be. If the policy depends to a large extent on whether it can be implemented by a few major international corporations, not to consult them in the formulation of the detailed policy seems unwise. We note that the Intelligence and Security Committee has come to a similar conclusion." (p. 22)

"57. The evidence we received shows that United Kingdom CSPs were not given any details about the possible content of notices before the draft Bill was published, overseas CSPs were not consulted about the draft Bill at all, nor was there any further public consultation."  (p. 22)

"58. Before re-drafted legislation is introduced there should be a new round of consultation with technical experts, industry, law enforcement bodies, public authorities and civil liberties groups. This consultation should be on the basis of the narrower, more clearly defined set of proposals on definitions, narrower clause 1 powers and stronger safeguards which are recommended in this report. The United Kingdom and overseas CSPs should be given a clear understanding of the exact nature of the gap which the draft Bill aims to address so that those companies can be clear about why the legislation is necessary." (p. 22)

5. The lack of a public consultation:

"56. The Home Office should not have assumed that a consultation paper published in April 2009 could justify publication of draft legislation three years later without further consultation with the public and with those most closely affected by its proposals." (p. 22)

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December 11, 2012 | Peter Bradwell

Joint Committee slams Home Office's Snoopers' Charter

They came, they scrutinised, they dismissed.

At 00:01 last night, almost exactly 14 days before Christmas, the Joint Committee on the draft Communications Data Bill delivered an early present. 

The MPs and Lords that had been tasked with scrutinising the Snoopers' Charter delivered a withering assessment in their final report.

The report concludes it pays "insufficient attention to the duty to respect the right to privacy, and goes further than it need or should."

They slammed the Home Office for 'fanciful and misleading' evidence, and for failing to consult on their plans. They said the costs of the draft Bill would exceed the predicted £1.8bn by a 'considerable margin'.

As a result of their insular and secretive policy process, the plans would create 'sweeping' powers that are far too broad.

The Committee also notes that the Government need to rethink how it defines the data involved in digital surveillance, creating a new hierarchy based on levels of intrusiveness.

It adds up to a damning indictment of the proposals and how they were put together. The cross-party Committee examined this draft Bill in extreme detail and with great care over the past 6 months. And they have found the Bill did not bear such scrutiny.

Two things should happen now. We think it's time to drop these dangerous plans and for the government to go back to the drawing board. Second, we need a fundamental, public review of digital surveillance. That's the only way we'll arrive at reasonable, proportionate proposals.

Given what the Committee have said about the Home Office's failures so far, and also given that such a review would involve broader question of justice and civil liberties, this review should not be run by the Home Office.

The findings of the Joint Committee echo the arguments put forward by Open Rights Group and its supporters over the past six months. A big thank you if you responded to the Committee's call for evidence - the report notes that these submissions reflect 'the anxiety felt by large sections of the public about intrusion by the authorities into their private lives.' 

You can read the full Joint Committee report here.

A shorter ORG briefing is available in the 'Our Work' section. More analysis of the Committee's final report will be posted through the day. 

You can read ORG's written submission to the Joint Committee in the 'Our Work' section.

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December 10, 2012 | Ruth Coustick-Deal

ORG Law Fund: Nearly there!

We need just thirty more supporters to reach our goal of funding a new Legal Officer! Please join and help us launch our legal project.

Across November we’ve been running our ORG Law Fund campaign to gain 150 new supporters – enough to fund a part-time Legal Officer for ORG. We took on our first legal case this morning and hope that this is one of many to come, with a legal expert in-house to guide our policies and provide knowledge of the courts and proceedings to ensure we are effective in defending your digital rights. Please read more about what the new position will do here.

We’ve nearly got enough to make it: We now have  the equivalent of 122 members

Thank you to the generous supporters who have been giving double what we ask for. We wouldn't be able to do the work we do without the support of people like you.

Please help us reach our goal and get to 150 by Christmas. We just need thirty new supporters to make it!

You can help us change the internet, set legal precedents now and frame the conversation regarding regulating the internet for the future.

There are more and more victims, like Paul Chambers, being arrested for free speech on social media. BPI are increasing the number of web blocking injunctions with insufficient transparency about what will be blocked. GoldenEye still wish to gain personal details relating to thousands of IP addresses because of alleged copyright infringement.  

All of these cases could just as easily be you – arrested for a joke on Facebook, finding your website blocked or your personal details blindly handed over to private companies by your ISP. Joining today allows us to stand up for your rights, enabling us to offer pro bono advice when these situations occur.

As part of the campaign I interviewed a number of ORG supporters,  illuminating all the different reasons people get involved with ORG – and the eclectic range of issues we deal with. They had some great things to say about what they think are the key issues for digital rights and how they first got involved. It was a particular honour to hear these words spoken by such different people when I asked them why they supported ORG:

  • Neil Gaiman spoke strongly about how ORG stand up for creators’ rights against monolithic laws
  • Becky Hogge talked about ORG representing the public interest in the copyright debate
  • Cory Doctorow was worried about computers becoming snitches rather than father confessors – and thought ORG protecting us from all that was amazing
  • Ben Hammersley’s key concern was that people realise that the internet is for everyone and thus everyone should be concerned about the threats to digital rights that ORG campaign on.

Although our Advisory Council members all have different backgrounds and passions they all felt that ORG do so much for the whole country, with our technical expertise and rational vision for the future that, for £5 a month, supporting ORG is a bargain and a wise choice.

This month there are even more reasons to become a member of ORG. It was wonderful to be awarded the Human Rights Campaigner of the Year Award by Liberty in recognition for our work on the Snoopers’ Charter. We’ve take on our first legal case, we’re organising a mass MP lobby day for next week and are building a national campaign against the Communications Data Bill.

With an in-house legal expert able to offer advice, co-ordinate our lawyers and take on new projects ORG will be able to deal with more issues like these.

Please help us make our goal – just thirty new supporters and we’ll be launching our major legal project in the new year!

Join today!

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December 06, 2012 | Jim Killock

Nearly there: £550 needed for GoldenEye appeal!

Update 7 December: we have raised the total!

We’ve raised an astonishing £4,450 so far in our GoldenEye Appeal – which is very encouraging. Many of these donations have come from people who heard about us from news coverage, and have newly placed their trust in ORG.

GoldenEye are seeking the names and addresses of O2 and Be Broadband customers to send them accusations of copyright infringement. We are challenging this.

We’re still short of £550 – which we’d really like before the appeal is heard next week, on 10-11 December.

Please donate if you can!

However, the biggest task with challenging GoldenEye is the need of staff time and expertise to understand the legal implications and opportunities. We’re also extremely keen to find, analyse and republish court injunctions in relation to website blocking.

We want to be able to intervene in future web blocking injunctions: either as a party or friend of the court. We want to be able to argue for transparency and accountability, which as we saw this week, is sorely lacking.

That’s why we need another 30 or 40 people to join ORG so we can start our legal project. Please join today!

Update at 12.15pm: we need only £150 more! 

Update 7 December: we have raised the total! 

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December 05, 2012 | Jim Killock

BPI remove from Pirate Bay block list

The BPI have this afternoon confirmed to us that they have asked ISPs to unblock as the organization responsible for maintaining the list of sites blocked under the injunctions to block the

On Monday, ORG wrote to Virgin, BT, O2, TalkTalk and Sky to ask them why the is being blocked. Virgin confirmed to ORG that the site was supplied to them as a domain to be blocked.

Under the terms of the blocking injunctions, the BPI instruct providers that are subject to the injunctions to block:

“ its domain and sub-domains and any other IP address or url whose sole or predominant purpose is to enable or facilitate access to The Pirate Bay website.”

The had been listed as one of those domains, according to Virgin, and thus it was up to the BPI to instruct the ISPs of the mistake.

We therefore wrote to the BPI to ask them to correct the problem. They wrote back to say that they yesterday instructed ISPs to lift the block.

The incident is rather revealing: it firstly shows that there is a significant need for greater transparency about the nature of blocking injunctions. Secondly, it shows that the BPI have been given a great deal of discretion over what may be blocked. Thirdly, it shows an alarming lack of transparency about what precisely is blocked. Neither ISPs nor the BPI seem keen to disclose what is on the list. It is effectively secret.

We have also written to rights holders, ISPs and groups interested in free speech if they would like to help us with creating a mechanism for greater transparency surrounding injunctions. While injunctions are public documents, they are not routinely published, and require significant resources.

We are likely to get greater resistance around the blocked lists. We will explore this, because, as we have seen this week, it is very problematic.

We’ll be running this transparency website if we get to 150 new members to start our legal project: so please join so we can get going! We’re nearly there – but still need help.

We’re also interested in what the next steps for the IETF’s Error 451 will be: the RFC ends in January. These errors could be very useful for standardizing responses and helping users locate why the blocks take place.

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December 03, 2012 | Jim Killock

PromoBay block

Reports from TorrentFreak that the legitimate website is being blocked by several UK ISPs highlights some of the problems with website blocking as a strategy and practice.

Promo Bay is republishing entirely legal content that nevertheless originates from the Pirate Bay. It does not deserve to be blocked, and it is unclear why it is blocked.

We think there are two likely reasons this block is in place:

(1) The site may be hosted at an IP address that is used by the Pirate Bay. This would be a classic example of ‘over blocking’, mandated by law. This wasn’t the intention:

As Mr Walsh explained, it is straightforward to prevent that method of circumvention by using IP address blocking. IP address blocking is generally only appropriate where the relevant website's IP address is not shared with anyone else. If it is shared, the result is likely to be overblocking (see 20C Fox v BT (No 2) at [6]). In the present case, however, TPB's IP address is not shared. Thus IP address blocking is appropriate. Accordingly, the Defendants have agreed to orders which require IP address blocking

Nevertheless it could be argued that the site could move IP address. This may be possible – but equally if the IP address is tied to TPB’s ownership in any way, it might get blocked again.

(2) The site’s domain may be on a list of domains deemed to be copies of the Pirate Bay in the court order. If so this is an error. 


ORG has written to the ISPs that are subject to the order today, to find out exactly what has happened. To be clear, we think the problem is less likely to be with the ISPs than the way the blocking orders are working. Furthermore, it is unclear what would be needed by the ISPs to get the block lifted, and what mechanisms are envisaged by the High Court to deal with these kinds of issues.

However, the wider policy ought to cause some concern at this point. The site that is blocked is publishing material that is both legal and promoting independent musicians. Censoring such material should hardly be a result that the music industry wishes to see.

But these results are the likely consequence of a policy of blocking. Censorship is an emotive issue. It betrays power relationships. Innocent sites can be caught. It fails to deal with the root problems, and can even reduce pressure to do so. At ORG, we contend that there are better ways of dealing with infringement than blocking:

  1. target companies with legal action;
  2. use legal avenues to stop commercial interaction with infringement;
  3. continue improvements in meeting demand with supply and give consumers what they want.

Blocking does not seem to be reducing infringement, but nevertheless music revenues are going up, largely because of the growing success of legal services. That's the way forward, rather than getting invoved in largely pointless battles that merely tarnish the industry's name while driving problems further underground.

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December 03, 2012 | Lee Maguire

Tales of the Unexpected: the Communications Data Bill

Police cited botched, corrupt investigation as reason to spy on the nation

We await with interest the report from the joint committee on the draft Communications Data Bill, and trust the committee has properly considered the substantial evidence submitted. The debate is hotting up, with Theresa May pitching hard in the Sun.

We are very interested to see if the Committee took a look at the submission by Caspar Bowden on page 102 of the written evidence highlighting the testimony given by Peter Davies (Chief Executive of the Child Exploitation and Online Protection centre), in support of the draft Bill. Mr Davies gave an example of a murder case in Lincolnshire in which increased data retention could have helped.

A check on the internet for the details of the case show a rather different picture. Rather than featuring a communication data problem, the case was one in which the police failed to properly investigate the murder. Worse, it later emerged that a corrupt police officer had been feeding police intelligence about the victims — to the murderer.

Not perhaps the best example to give as the Home Office ask us to trust the police with huge amounts of new intelligence gathering.

… there is a much grave concern about the good faith of the police evidence to the Committee on 12th July, when it was stated: 

(Q142) Peter Davies: For some time it has been possible, roughly or more precisely, to locate a mobile telephone through the use of communications data. A team I have led has used that as almost the sole means of detecting a serious double murder in one of my previous forces ....(Q146) ...related to a retired couple shot dead in their home on the coast of Lincolnshire in August 2004 by, as it turned out, the pre-eminent organised crime group then operating in Nottinghamshire. Bluntly, without communications data relating to contacts between mobile phones it would not have been possible to detect that crime and lock up the people responsible. ..(Q147)...Bluntly, there were other people involved in the conspiracy whom it might have been possible to prosecute and convict, but who it but who it was not possible to prosecute and convict because there was a data loss in that investigation

Tracing this case using the details provided leads to news reports suggesting this account is materially misleading :

Police failed to protect innocent couple executed in gangland revenge attack, damning watchdog report reveals

The IPCC upheld five of seven complaints made by the Stirlands' family. They found:

• After the shooting incident at their Nottingham home, Mr and Mrs Stirland were given neither protection nor help by Nottingham police.

• That incident was "not properly investigated, despite rumours circulating about who was responsible".

• Nottinghamshire Police's failure to share intelligence with Lincolnshire Police about the threat to the Stirlands was "unacceptable".

• The response to Mrs Stirland's call about the prowler was "delayed and unsatisfactory".

Moreover it emerged two years later at the inquest that

Stirland revenge hit men 'known before killings': Police had identified Nottingham crime boss Colin Gunn's team of six hit men weeks before two killed a couple in a revenge attack, an inquest jury heard....The former officer, who remained anonymous, said the two men who killed the Stirlands had been named as part of Gunn's team of hit men.

Although this case was offered in evidence as an illustration of the necessity of blanket data retention, in actuality it precisely illustrates how diligent and proactive use of targeted data preservation could both prevent and detect crime. Had communications data preservation commenced promptly about suspects identified weeks before the crime, prima facie police might well have been able to prevent the crime as well as catch the perpetrators. Furthermore, it emerged, contrary to the conclusions of the IPCC investigation that:

Corrupt officer fed data to Colin Gunn on Stirlands: A corrupt detective searched Nottinghamshire Police computers for intelligence about a couple killed in a gangland execution, an inquest heard.

It seems ironic that the police cite a fatal case of police corruption and its subsequently botched investigation, as justification for blanket retention of data about the entire population. It would be more logical to propose blanket retention of data on the entire police force. This is probably not the conclusion drawn by the Committee from the evidence heard.


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November 30, 2012 | Jim Killock

Data protection debate at MoJ

Yesterday I attended the first of the Department of Justice's Advisory panel meetings on the new Data Protection regulation laws being proposed at the EU.

The new laws are already the subject of intense lobbying and pressure. The key changes are designed to strengthen the privacy rights of citizens, in several ways:

Better definitions: the definitions of personal data and consent have caused problems especially in the UK, where we haven't followed the Directive strictly. The result is that some personal data - like that collected by behavoural advertisers - is not treated as personal data; and sometimes consent is "implied" rather than actually freely given and explicit.

The right to be forgotten: perhaps better understood as a right to have data deleted in full, when you choose to exit a service. The debate is about how easy it is for a service to request data be deleted by third parties that it works with, when your data has been shared

The right to your data: in the UK, getting your data back costs £10. In other coutries, it is free. The new law proposes you get it back for free, and in electronic format so you can move around different data services easily. Some businesses claim that this would lead to frivolous claims, and want to limit your ability to get your data. We argue it should be possible for bigger businesses to make it easy by building the systems right.

Put together, the right to delete in full and get your data back are meant to create a market for individuals to be able to choose data services and drive the market.

Increased fines based on turnover: this would create a real and scalable deterrent, reflecting penalties in competition law.

Damages that are based on the sigificance of a breach to a person, not proving financial or personal harm: data breaches put you at risk and are a harm in themselves. In the UK, you must prove actuall loss, or stress, or some other tangible harm to take someone to court. This is too high a bar and means most people cannot complain to a court.

Breach notification: while longer than 24 hours speficied in the draft is needed, you should have a right to be told of a data breach.

Group actions: the regulation would allow groups like Which? or ORG to represent groups of affected citizens in a particular case.

EU consistency: by choosing a regulation, the new data protection law would be written straight into UK law, so would be the same as other countries. This would reduce the burden on business, improve predictability for citizens and hopefully make it easier for people to enforce their rights.

There was of course a lot of disagreement about the big issues, like what to do with the right to be forgotten, or how data portability should work. The meeting was conducted on Chatham House rules, so I can't name names, but this may give you a picture.

There was surprising consensus that a unified European data protection law would be good for everyone: business, small businesses and citizens, by making it easier for people to know their duties and rights wherever they are. The group felt this should reduce the burden on business overall.

This placed the government's current position of opposing a new, tighter "regulation" as failing to represent the consensus among those parts of UK society represented at the meeting. This included major businesses, small businesses, policing and civil society. Despite the government's desire to limit the changes to data protection, the advisory group seemed to be prepared for change, and without a doubt wanted greater legal consistency.

There are also seemingly contradictory positions within the UK government, where BIS are trying to increase data portability through domestic legislation to support Midata, but Justice are resisting it at the EU.

The real arguments will come as US businesses and government lobbyists try to weaken the regulation. Right now, UK citizens' interests need to be better reflected by the government, who should be supporting greater control over our personal information.


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