From the ICO:
An undertaking to comply with the seventh data protection principle has been signed by Aberdeenshire Council after a paper file was lost by an employee of the Adult Mental Health section of the council’s Social Work service. The employee had placed the file on the roof of his car before driving off.
The file was later recovered and, though it could not be confirmed definitively, there was no evidence to suggest that its contents had been subject to unauthorised processing.
The ICO’s investigation revealed that the employee had never received data protection training prior to the incident.