Upgrading online services can introduce additional risk, and especially when personal data is involved.
It is reported that a company providing a register of millions of pets microchip details, may have run into problems following an upgrade to its online services and database.
The company insisted that the data had been safely and securely migrated (here is their full statement at 30th March 2021). It did however, mention that human error caused an incorrect record to be displayed to a customer online.
What can we learn from this, for our next migration project?
Well, I hope that your Data Protection Officer or nominated person will be very closely involved from the start, to build in ‘data protection by design and by default’ into not only the new database but also the migration process. Liberal use of DPIA’s, and clear project management and risk management strategies, should help you to stay safe.