Whats all this about?
Last week I attended the Commissioner’s conference at the Lowry Hotel in Salford (a suburb of Manchester), which launched the public consultation stage of the ICO's proposed "Personal Information Online Code of Practice". The first speaker was Christopher Graham, who reminded us of the achievements of a former local MP, Hilaire Belloc. Between 1906 and 1910 he represented the constituency of Salford South.
More commonly remembered as the Roald Dahl of his day, Belloc’s cautionary tales serve to remind us all of how we ought to behave. And Christopher Graham took the opportunity to refer to the regulatory landscape and to remind us of two elephants in the room, the Article 29 Committee and the European Commission, both of whom were struggling to apply an outmoded Data Protection Directive to the business needs of a world which simply did not exist when the Directive was agreed.
The inference was that the pragmatic approach adopted by the ICO was at risk of being challenged of it, or UK data controllers, were to be seen to be overstepping the mark too blatantly. So, it appears that, as a body, we all need to agree which parts of the law we should apply rigorously, and which parts deserve to be glossed over (because they are unduly onerous, burdensome and simply don't make any sense any more). The inference was that unless we moved as a body in deciding which bits to ignore, the Commission might well take it upon themselves to pick off the stragglers.
So we have been warned. We must all pull together – and then we’ll be permitted (as they say in sailing terminology) to shift our course away from that adopted by the rest and tack away in another direction.
But Christopher Graham didn’t use nautical terms. Instead he used medical terms, by referring to the story of “Jim” – which advises us that we should
“Always keep a-hold of Nurse
For fear of finding something worse”
So, if the main players within the ICO are to be cast in medical terms, then just who are the key characters at the re-jigged Wilmslow Information Hospital? I hear that there’s just been another reorganisation up there, and perhaps soon we’ll learn who’s now in charge of what. But, in the meantime, my suggestions for new job titles are:
Information Commissioner --- Matron
Chief Operating Officer --- Midwife Higher Level (Research Projects)
Director of Human Resources --- Health Visitor Specialist
Deputy Commissioner Data Protection --- Health Visitor
Director of Comms and External Relations --- Nurse Team Manager (Learning Disabilities)
Assistant Commissioner Freedom of Information --- Theatre Nurse
Head of Regulatory Action --- Nursery Nurse (Communities)
Corporate Governance Manager --- Clinical Support Worker
Other suggestions would be welcome until the official structure is known.
Oh, and by the way, for those really interested in “Jim”, Hillaire Belloc’s poem about the boy who ran away from his nurse and was eaten by a lion is set out below:
There was a Boy whose name was Jim;
His Friends were very good to him.
They gave him Tea, and Cakes, and Jam,
And slices of delicious Ham,
And Chocolate with pink inside
And little Tricycles to ride,
And read him Stories through and through,
And even took him to the Zoo--
But there it was the dreadful Fate
Befell him, which I now relate.
You know--or at least you ought to know,
For I have often told you so--
That Children never are allowed
To leave their Nurses in a Crowd;
Now this was Jim's especial Foible,
He ran away when he was able,
And on this inauspicious day
He slipped his hand and ran away!
He hadn't gone a yard when--Bang!
With open Jaws, a lion sprang,
And hungrily began to eat
The Boy: beginning at his feet.
Now, just imagine how it feels
When first your toes and then your heels,
And then by gradual degrees,
Your shins and ankles, calves and knees,
Are slowly eaten, bit by bit.
No wonder Jim detested it!
No wonder that he shouted ``Hi!''
The Honest Keeper heard his cry,
Though very fat he almost ran
To help the little gentleman.
``Ponto!'' he ordered as he came
(For Ponto was the Lion's name),
``Ponto!'' he cried, with angry Frown,
``Let go, Sir! Down, Sir! Put it down!''
The Lion made a sudden stop,
He let the Dainty Morsel drop,
And slunk reluctant to his Cage,
Snarling with Disappointed Rage.
But when he bent him over Jim,
The Honest Keeper's Eyes were dim.
The Lion having reached his Head,
The Miserable Boy was dead!
When Nurse informed his Parents, they
Were more Concerned than I can say:--
His Mother, as She dried her eyes,
Said, ``Well--it gives me no surprise,
He would not do as he was told!''
His Father, who was self-controlled,
Bade all the children round attend
To James's miserable end,
And always keep a-hold of Nurse
For fear of finding something worse.
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