Earlier this year, Women’s Aid approached the ICO with concerns around the mishandling of personal data by tracing agents, individuals tasked with locating and reporting on an individual’s whereabouts. There were concerns that agents were sharing survivors’ locations with their abusive ex-partners, endangering survivor safety and security.
In response, the Information Commissioner's Office (ICO) investigated practices in the sector, including the safeguarding procedures followed by tracing agents and the requirements of their professional body.
The ICO’s enquiry found no evidence that tracing agents had been involved in sharing survivors’ details. Many of the tracing agents they spoke with demonstrated an understanding of the potential risks to survivors, emphasised obtaining consent before sharing personal data, and refrained from tracing individuals believed to be in vulnerable situations.
As part of their enquiry, the ICO looked to charities, including Respect and our membership, to gather further information on the issue. Whilst these conversations did not reveal evidence of the misuse of information by agents, they highlighted the ease with which perpetrators exploit accessible and affordable technology to track and harass victims. This behaviour is something consistently flagged by Respect members, and we are working with UCL’s Gender and Tech Research Team to ensure staff in perpetrator services have the skills they need to respond to tech abuse.
Key Findings and Recommendations
Following their investigation, the ICO has made a series of recommendations around data protection practices within the tracing agent sector, including:
- following safeguarding policies and managing risks e.g. by conducting Data Protection Impact Assessments
- recommending that all tracing agents integrate data security and privacy measures into all their activities
- recommending they should conduct an audit of their policies and procedures to ensure they are compliant with the law
In their response to Women’s Aid, the ICO reiterate their ongoing commitment to work alongside the domestic abuse sector to ensure organisations are handling survivors’ information appropriately and taking measures to keep them safe.
