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Posted
If you have a log of all internet access you don't need a screenshot, you could have the html

 

Except the Internet isn't static these days. You could visit a page and get a very different view than I get. Add to that HTTPS interception issues.

 

I'm not condoning or endorsing, but saying you just need a link to see what they were looking at is incorrect.

Posted

First things first, ask for the DPIA to be completed.

It will have on there the purpose, the lawful basis, consideration for things like would they expect for their data to be used in this way (and saying "our contracts and policies say it is ok!" is not the right answer).

It needs to cover retention, security of the data, etc.

 

If it has not been done before, it is a new type of processing ... so *has* to have a DPIA completed. That needs to be agreed by the DPO (and if any disagrees with what the DPO recommends then that gets logged). Whilst the DPO does not need to be approaved by the Board/GB, for something as significant as this, it should be raised that one is being completed ... and I would expect that the relevant link Trustee/Governor has many questions to ask on it.

 

Let's just say that most DPOs would have a lot to say on this!

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