Third Party Bulk Personal Datasets (3PD)
A third party bulk personal dataset (3PD) is a dataset which would fall within Part 7 of IPA 2016 if an intelligence service were to retain it, but which is instead held by a third party (such as Government departments or commercial entities).
	For example, an intelligence service may access Government-held immigration related datasets to conduct checks to ensure those entering the UK do not pose a risk to national security. Many commercial companies acquire various datasets as part of their own business objectives and offer access to these to a variety of customers. Access to such datasets may offer the intelligence services different capabilities and insights to those that are generally available in order to support them in carrying out their statutory functions. It may be more proportionate or practical for the intelligence service to examine in situ a dataset held by a third party rather than acquire and retain the data themselves.
	The Act inserts a new 3PD regime into the IPA 2016 that would apply where an intelligence service has relevant access to the 3PD and examines it in situ (that is, on the third party’s systems) for the purpose of their statutory functions (see the Security Service Act 1989 and the Intelligence Services Act 1994).
	The new regime introduces 3PD warrants, which will be subject to a "double lock", whereby the warrant would need to be approved by both the Secretary of State and an independent Judicial Commissioner. This would build on the statutory regime that already exists in the IPA 2016 to underpin other powers.
	Lord Anderson’s review of the IPA 2016 noted that the Investigatory Powers Commissioner’s Office (IPCO) conducted an ‘extensive review’ of third party datasets in 2019 and concluded that the intelligence service’s current access was compliant with Part 7, as reported in IPCO’s 2019 Annual Report 4 . However, IPCO’s report recommended that the Government consider bringing third-party datasets within IPCO’s oversight. The new regime draws on the already well-established Part 7 IPA 2016 regime and incorporates statutory safeguards, including making provision for independent judicial oversight by the Investigatory Powers Commissioner.