Hi all
At BL we have opted for a more narrative approach to recording Article 30 information. We have set up Article 30 Case Files (organised by Department/Team) that contain a folder for each process within that Team that uses personal data (where that Team owns the process). Each folder contains a process map, a DPIA, an Article 30 Report and any supporting information such as contracts, templates etc.
High level summaries of each process (with links to relevant case files) are stored on a spreadsheet so it can be searched easily when required. Seems to be working well for us and doesn’t require any third party systems, fancy software or cumbersome spreadsheets.
I've attached our word doc Article 30 Report that I drew up in case it can be of use to anyone. Happy to talk through our approach in more detail with anyone who wants.
Kind regards
James
James Courthold
Information Compliance Manager
Corporate Information Management Unit
T +44 (0)20 7412 7565
[log in to unmask]
The British Library
96 Euston Road
LONDON
NW1 2DB
www.bl.uk
-----Original Message-----
From: This list is for those interested in Data Protection issues <[log in to unmask]> On Behalf Of Maureen Wilkinson
Sent: 24 August 2018 14:11
To: [log in to unmask]
Subject: Re: [data-protection] Systems for complying with Art. 30
Hi Chris
That's exactly the situation we're in. We have an unwieldy spreadsheet with almost a thousand lines and its still growing. We need the ability for our business functions to be able to 'self-serve' whilst giving the governance team the ability of oversight.
Everything we have looked at so far doesn't look like it could manage an organisation of our size/complexity without paying huge upfront costs and/or large annual licence fees.
We're looking at this not only from a compliance perspective, but also to look at where there may be duplications of efforts/storage etc
Happy to share ideas with anyone who is also looking at this!
Maureen
Maureen Wilkinson
Chief Information Security Officer
Information Security & Governance Team
IT Service
Newcastle University
NE1 7RU
-----Original Message-----
From: This list is for those interested in Data Protection issues <[log in to unmask]> On Behalf Of Chris Spray
Sent: 23 August 2018 20:46
To: [log in to unmask]
Subject: Re: [data-protection] Systems for complying with Art. 30
Phil, that's just what I was planning to do, but advice I had and the ICO example on their website seems to demonstrate that is not granular enough.
The ICO template for example has for purpose of processing "recruitment" by "HR" the example categories of personal data for "successful candidates" are shown as contact details, qualification details, employment history, ethnicity and Disability details. And then you go through the same listing of types of data for "unsuccessful candidates", and then for "personnel file" there is another list and so on across all business functions and processing activities.
For organisations with many different processing purposes and activities, trying to follow the template can make for an unwieldy document with potentially hundreds if not thousands of lines of data, especially if you go strictly by article 30 wording and you transfer data to other countries you appear to have to list each country individually for every processing activity.
A "system" that enables (and prompts) business functions to maintain and update their own records whilst providing a central sight of all business functions for governance functions starts to look attractive.
Chris
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Phil Bradshaw
Sent: 23 August 2018 15:47
To: [log in to unmask]
Subject: Re: [data-protection] Systems for complying with Art. 30
Do you need a system?
Start with your previous notification document, add a link to your (hopefully thorough) privacy notice(s), RM policy and retention schedule, IT security policy, and I think you have covered R30.
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