Whilst the data controller has complete responsibility for renewal in my
opinion and probably in fact, there would be great advantages in the ICO
analysing the notification data in certain ways to generically identify
potential problem areas.
Such actions would not change any of the data controller’s responsibilities
and would not necessarily mean the ICO became an intrusive organisation more
reliant upon coercion to regulate. Certainly analysis of that type would be
completely in line with the file which used to be stated to be maintained on
every DPO by the ICOs office.
Considering that file makes one wonder which record(s) the BT difficulties
would be recorded on. If the existence of that register has continued no
doubt there will be a state of the art data protection compliant CoP or set
of governing rules providing fairly detailed guidance determining such
issues.
All this raises thoughts of which notification purpose such a register would
be recorded within, and whether ICO regulative practitioners of all types
are profiled the same.
Ian W
> -----Original Message-----
> From: This list is for those interested in Data Protection
> issues [mailto:[log in to unmask]] On Behalf Of Tim Trent
> Sent: 14 February 2006 16:08
> To: [log in to unmask]
> Subject: Notification renewals
>
>
> 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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