108
IPCO Annual Report 2018
MOD
FCO
Home Office
1
NIO
4
SIS
GCHQ
27
122
MI5
0
20
40
60
80
100
120
140
Figure 21: UKIC errors by department and agency, including interception and
CD, 2018
UKIC Communications Data (CD) errors
17.18
The relevant Codes of Practice (CoP) outline the point at which errors occur and the actions
required to be taken by an agency or a Telecommunications Operator (TO). When an
approved application for targeted CD is initiated, or a notice served on a TO, there are two
categories of error: recordable and reportable.
What is a recordable error?
A recordable error is one that has been identified by the agency without any data being
incorrectly acquired or disclosed. A list of recordable errors is retained by an agency. The record
explains how the error occurred and provides an indication of the steps taken to prevent a
reoccurrence. At each inspection, the list of recordable errors is audited and, if necessary,
observations or recommendations are made in inspection reports to tighten procedures or
processes. An example of a recordable error is when an analyst manually transfers data to a
system and inputs the information incorrectly, making a transposition error which does not
result in the acquisition of incorrect data.
What is a reportable error?
A reportable error occurs when incorrect CD is acquired; such a disclosure to an agency could
infringe on the rights of an individual unconnected to an operation or investigation. Reportable
errors should be recorded within five working days of their discovery. The error report explains
how the mistake occurred, indicates whether any unintended collateral intrusion has taken
place, details and confirms the destruction of data and provides an indication of steps taken
to ensure similar errors are not replicated. When a report is made, the appropriate Senior
Responsible Officer (SRO) must be sighted on the error to enable, if necessary, any strategic
changes to policy or procedures.