Renewal of notification is 100% the responsibility of the data controller.
The UKIC sends out a renewal notice and also offers direct debit as a
payment (and thus continuity) mechanism. But his office reasonably regards
currently it as simply the responsibility of the data controller to renew.
After all, items may have changed.
It would be interesting to see if he has powers available to him like the TV
Licencing people or the DVLA to impose sanctions based on a presumption of
the need to notify or to renew.
I would support such powers. They might well give him sufficient revenue to
employ sufficient staff to enforce the rest of it.
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Ian Welton
Sent: 14 February 2006 15:48
To: [log in to unmask]
Subject: Re: [data-protection] FW: [data-protection] BT notification
Expiry analysis by the ICO may not be carried out then. I wonder when the
notification was due to be renewed or/and how many other large controllers
have not renewed. No doubt reflection on administrative processes would
assist.
Notification certainly used to be a particularly useful basis for reviewing
and maintaining some knowledge within an organisation during the data
compilation and notification process although greater collections of data
often used to be known to generate little information.
When exercising data controller responsibilities within complex
organisations there must logically be some valuable corporate knowledge
generated from the administrative processes involved which inform many other
spheres.
Ian W
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