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  • In terms of "published", what if it's stored and not published? What are 'reasonable means' required to protect an account number? Will a password protected login do or do the ICO require this data to be encrypted? Do these requirements change if the account details are linked to an individual?

  • What do you mean 'only store collections of identifiers'? Where is the actual data then? It needs to be linked up for use, which would mean it could be linked by someone compromising the database while at rest, no?

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