On Wed, 18 Nov 2009, Broom, Doreen wrote:
> I'm surprised at your policies only being 2 pages long. Our Data
> Protection Policy which has gone through the Plain English Campaign is
> 25 pages long, I also have Procedure document which is about the same
> length. Staff guidance documents are usually only 2/3 pages long and
> they are very basic. When dealing with sensitive personal data, data
> sharing, proposed fines/imprisonment for data leaks etc. and all the
> other areas in the Council we could not take that chance. There is a
> separate Security Policy which does link with the DP Code of Practice
> and vice-versa.
Generally, on policies:
In my experience, what you describe is probably the wrong way around.
Most parent policies should, as previously commented, be clear, easy to
read, and not terribly specific at anything. They should provide very
general points, and not prescribe particular procedures, tools,
technologies, and whatnot. Policies are usually to be approved at a
senior management level, and as such should not change frequently: too
much detail means too much likelihood to change, and that can be a
drawn-out procedure. The role of senior management is to approve general
principles of policy, not to get bogged down in operational and procedural
detail and practice.
Policies should devolve responsibility for creating and approving related
procedures, guidance, best practice and other more detailed documentation
to other bodies or committees. These documents are still controlled, but
are more dynamic, and can be easily modified to suit circumstances but
without the time-consuming senior management approval route. They are the
ones that are usually referenced day-to-day by end users, but breach of
them is considered breach of the parent policy to which all staff agree to
abide.
I don't know your policy of course, but it sounds like there should be
more of the detail moved to the staff guidance document, and less in the
actual policy itself. If the Policy describes specific ways of working or
procedures, it probably should be rewritten to move that detail to other
documents. Documents bearing titles such as "XYZ Policy" are often
mixtures of policy and procedures or guidance/best practice rather than
actual "statements of policy".
Jethro.
>
> -----Original Message-----
> From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Tony Brookes
> Sent: 18 November 2009 17:25
> To: [log in to unmask]
> Subject: Re: Data Protection and Information Security Policies
>
> Having just gone/going though in another University, I hope this will
> help. We have suggested an information security policy as the "top"
> information policy backed up by our version of the PIP. I'd then expect
> a load of other policies to support them both (e.g. records managment,
> techncial policies etc etc). Note - we've come to the conclusion that no
> policy should be more than two pages long, but the associated guidence
> may well be much longer than that. It is a similar approach to that used
> in H & S.
> Mind you, I'm well aware that what works or is being tried in one
> University might not suit another. Tony ________________________________
>
> From: This list is for those interested in Data Protection issues [[log in to unmask]] On Behalf Of Tim Trent [[log in to unmask]]
> Sent: 18 November 2009 16:10
> To: [log in to unmask]
> Subject: Re: [data-protection] Data Protection and Information Security Policies
>
>
> I would say that neither of these policies is what I would term a "master policy"
>
> Data Protection has many of the facets of Information Security embedded within it it. Examples are a Data Destruction Policy - very much required - and the additional security that must surround sensitive data. yet InfoSec is not a subset of Data Protection, nor is Data Protection, because of the privacy element, a subset of InfoSec.
>
> Instead these are two parallel and often intersecting areas where each policy and set of sub-policies must relate to the other stream, and where some policies - Data Destruction - need only exist in one or the other, but be referred to as part of each.
>
> Your mileage may vary, of course, but my belief is that the overall policy is the Human Resources Policy that covers disciplinary action against workers who break either (any) of the other policies
>
> On 18 Nov 2009, at 15:42, Barlow, Jackie wrote:
>
>
> Dear colleagues,
>
> I am fairly new to the role of Records Manager here at Anglia Ruskin and I
> have recently revised our Data Protection Policy. Our Information Security
> Policy is also currently being revised and I am unsure which of these
> policies should be the overarching one.
>
> I would be grateful for your opinions on this and any information on your
> current practices.
>
> Kind regards
> Jackie
>
>
>
> Jacqueline Barlow ACIB MBA
> University Records Manager
>
> Anglia Ruskin University
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> Direct dial 0845 196 4215
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