Colette,
It is simpler to work with if you consider the YOT's as data controllers and
treat the data that is "shared" with them almost as a normal disclosure, but
with documented restrictions which reflect the restrictions upon the data in
its original environment (Not dissimilar to a data processor agreement).
The YOT's are then fully responsible for that data and abiding by any
restrictions upon it, much the same as if they had collected it themselves
and were applying first and second principle issues.
Ian W
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]]On Behalf Of Colette Healiss
Sent: 19 March 2002 09:36
To: [log in to unmask]
Subject: Multi-Agency Partnerships
Dear All (and esp. Ian Buckland re your email today)
I have had some advice that there is guidance on the status of YoTs (Youth
Offending Teams) on the Youth Justice Board website at:
http://www.youth-justice-board.gov.uk/policy/90722_info_sharing_v0.3.pdf
This makes it pretty clear that YoTs at least should be notifying to OIC.
What I've got a problem with is that the intricacies of the relationships
involved in each type of partnership makes it enormously involved to work
out the responosibilities for DP. I just wonder if it would be simpler for
all concerned if there was a standard approach to these arrangements. I
was having a think about it yesterday and the best I could come up with was
as follows:
Multi agency partnership registers as a data controller for the purposes
which are specific to its remit.
Member agencies of the partnership each contract with the partnership as
data controllers in common (for the data which each member shares with the
partnership)
Member agencies contract with each other as joint data controllers (for the
data which they share with each other for partnership purposes)
I'm sure someone will be able to let me know why what I am suggesting is
patent nonsense. Would be glad of the feedback anyhow.
Cheers
Colette
St Helens Council
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