Hi Chris
I think this is really badly thought out by the auditors, I don’t know about the rest of the DPO's on here but I have plenty to be doing without having to review every SAR that goes out. We use a case management system for the SAR and FOI's so I can report on overall compliance. This should be all that auditors need.... test control = 90% of SARS being processed within 30 days and then the results of this in a percentage. The auditor can then report on compliance with the expectations.
The DPO should provide independent advice to the business on compliance with the law, not process what essentially is the bread and butter work from the frontline staff (and I know that sounds like I am degrading the work, this is not my intention)
Regards
Darren
DPO - Harrow Council
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Chris Tinsley
Sent: 11 April 2019 09:26
To: [log in to unmask]
Subject: [data-protection] DPO involvement in SAR process
Good morning all
An NHS organisation I support has recently been audited for GDPR compliance.
One area in which the auditors thought there was an issue was in the processing of SAR’s. They would like the DPO to have sign-off of all SAR’s both internal from staff and external from patients. The organisation receives relatively few SAR’s. The DPO is happy to this.
My view is that the DPO should not be part of the SAR process, it compromises her ability to act independently as she becomes part of the process. There is also a side issue of her being non-clinical yet signing off patient SAR’s.
I have asked the auditors to look at this again.
Is this an issue or have I just misjudged the role of the DPO
Regards
Chris
Sent by me
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