Yes it is. The trouble is the IG SIRI is a L2 and you report on the toolkit, the ICO are informed automatically whether you would have or not. The SIRI grading criteria doesn't quite seem to mirror, or say "see the DPA" their grading criteria is rather different.
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Baines, Jonathan
Sent: 29 November 2013 13:35
To: [log in to unmask]
Subject: Re: [data-protection] NHS notification of breaches
I think this is the key document, but NHS colleagues can no doubt clarify
https://www.igt.hscic.gov.uk/KnowledgeBaseNew/HSCIC%20IG%20SIRI%20%20Checklist%20Guidance%20V2%200%201st%20June%202013.pdf
Jonathan Baines
Complaints and Information Rights Officer Legal and Democratic Services Buckinghamshire County Council
01296 383681
Follow us on twitter @buckscclegal
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of GRAHAM Susan
Sent: 29 November 2013 13:21
To: [log in to unmask]
Subject: [data-protection] NHS notification of breaches
I have heard it said that it is standard practice for the NHS to notify all data protection breaches to the Information Commissioner, and that this is why so many of the monetary penalty notices relate to NHS organisations. Is there a policy document that sets out the NHS approach to breach notification and defines what should/should not be notified?
Best wishes
Susan Graham
--
The University of Edinburgh is a charitable body, registered in Scotland, with registration number SC005336.
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