Our audit section has just sent out a document relating to the above
initiative, which is essentially a fair processing notice to advise all our
employees that their payroll data will be matched with other payroll and
housing benefit data held by other councils across the country, as well as
internally with our own housing benefit data. There is no suggestion of
consent, and indeed the letter says this is a mandatory exercise.
The intention of course is to identify overpayments, and where fraud can be
proved, the letter threatens disciplinary action and/or criminal
prosecution. This is a national initiative run by the Audit Commission.
The letter was sent out to ensure they comply with DP, but although I
understand the Section 29 exemption, I am somewhat wary of this kind of
wholesale data matching, especially as I believe a third party company does
the matching, and I have seen no evidence of data sharing agreements
between this company and the Audit Commission as yet, although I'm sure
there must be something in place.
I'm also not sure whether this could be enforced in the private sector, and
if that is the case could see the potential for challenge to this on a
privacy basis under HRA, as it does not seem fair to subject public sector
employees to this and not the private sector.
My ideas on this are by no means crystal, but if anyone has any comments I
would certainly be interested. Any thoughts?
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