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21/04/2018: Countdown to Compliance - Week 5, Time to Audit Your Backups

By now, you should have received sample emails from me requesting your permission to keep in touch via email with news and other items of interest to anyone with a web site to promote their business.

In an ideal world, you will also have approved the wording and sent me an email saying either "Yes, send a similar mail on my behalf to the contacts in my site enquiries database" or "No, I would rather change the wording to...". If you haven't yet done so, now may be a good time to think about getting such an email sent to purge your enquiries database and make sure all the contacts remaining, do so at their request.

Enough of mailings though, that is so last week! This week, my message is about backups. Of course we all back up religiously, don't we? In the interest of business continuity, a reliable backup regimen is vital. Losing the main data repository can spell the end of trading for some businesses who have failed to keep a backup copy.

So, now may be a good time to think about what kind of backup policy we put in place. These generally fall into two categories; incremental and snapshot. In many built in backup applications, incremental backups are favoured as they generally run faster and take up less disk space. In an incremental system, the subject drive and its backup files are compared, then only those that show some change are stored. This means that everything from the first ever backup is kept and can be restored if necessary.

However, if any personally identifiable data are included in that backup, you may be falling foul of the regulations by keeping absolutely everything in this way. Like many others, I have now changed over entirely to a 'snapshot' type of backup where the entire contents of the disk are backed up as they are at that instant. This means that any data that have been deleted since the last backup no longer appear in the backed up version. Thus, when the last backup file is deleted, there is no possibility of inadvertantly storing any information that we should not. Or is there?

Well, the answer is probably yes, but it is unlikely. It is also going to be for a very limited time. Say for example, you back up weekly in the small hours of Sunday morning. Then on Monday, a contact exercises their right to be forgotten and removes themselves from your database. On tuesday, disaster streikes and your master hard drive needs to be replaced. No problem of course, as you have a backup copy, which you can restore and bingo! you are seamlessly back in business. The only minor fly scudding across the surface of this otherwise perfect pot of ointment is that in restoring the entire contents, the person whose data were removed on Monday has now been replaced.

To avoid this, I recommend keeping a record of all contacts who have been removed for a further seven days so that if there is a disaster and the latest backup is restored, you can manually remove the offending content permanently.

Don't forget to mention this buffer period in your data protection policies, so that nobody has any right to complain if they find you have held onto their information for an additional seven days.

As i say, the likelihood is small, but in a world where we must all be like Caesar's wife, beyond reproach, little things mean a lot.

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