I agree. I was approaching this from the fair processing requirement and
consider the questuionnaire may have some shortcomings as follows:
1. Who is data controller, The Authority or COSLA Job Evaluation Consortium.
2. Misleading the data subject by giving the presumption of anonymity when,
in fact, we are retaining details which identifies the individual
3. Failing to indicate that the questionnaire will be used for JE purposes
only
4. Failing to indicate who will have access to the information (other
organisations, managers, etc)
5. Although a Factor Framework is provided, failure to provide details of
the weighting of each factor, particularly when there is an automated
process, may be seen as a failure with respect to fair processing.
I agree that it should be relatively easy to correct these potential
problems to ensure compliance.
Alex Mitchell
North Lanarkshire Council
-----Original Message-----
From: Yuill, Allan [mailto:[log in to unmask]]
Sent: 19 June 2002 12:40
To: 'Mitchell Alex'; [log in to unmask] AC. UK
([log in to unmask])
Subject: RE: Data Protection and Job Evaluation in Scottish Local Authorit
ies
I'm from a Management Services background, via Personnel to IT (don't ask!)
so it's in my area of interest. It helps that my colleague supports the job
evaluation package used by all of the Scottish Councils and was on the
training course for one of the statistical analysis packages (one of
several options). So I've just grilled him about the information stored and
I am still convinced it is personal data as defined by the Act.
I've just read Paul's post and I agree from a training point of view, the
focus is on the post, not the person. If the personal information was
discarded and there was no reference back to the original interview, or the
information for each post was summarised, then I agree that it would not be
personal data. But this is not what happens in real life. In order to ensure
the system is fair and to backtrack to examine any inconsistencies, an audit
trail is maintained to support drill down in the statistical package to one
of several interviews for a particular post. A reference then links back to
the original job evaluation exercise.
However, I don't really see any data protection problems if it is identified
as personal information. All Employees, including those taking part in the
exercise are fully informed about what will happen to the information and
the background machinations to arrive at a job evaluation score have been
agreed with Trade Unions. As long as the extracted information is only used
for the original purpose, for statistical analysis only and identifies the
original interview by a code, then it complies with the DPA, in my opinion.
The only problem would be if the original data collection exercise was not
DPA compliant...
Allan
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