Full compliance would be extremely costly in terms of both staff time and resources. We believe that additional work needs to be done in this area, including the implications for national policy on the use of encryption, and we would be pleased to be consulted further. HE involvement abroad is an expanding area. For example there are franchise arrangements with colleges overseas, courses are run jointly by HEI's in several countries, growing numbers of students undertake exchange visits, research projects are often international. As well as providing valuable educational opportunities, such activities generate income.
Collaborations often have partners from both European and non-European countries.
2.4.2 Clear and simple operational guidelines will be needed for HE staff establishing international links, preferably with the same guidelines being used by colleagues across Europe. Data controllers should not have to tackle each case from first principles. If central arrangements to determine adequacy are made in the UK, the bodies concerned should work closely with colleagues in other Member States. Our preference would be a European Community wide initiative. Simple, enforceable guidelines about publishing personal data using such media are needed.