Perhaps other members of the list serve who have already coped with
implementing changes to HR procedures due to the DPA may be able to comment
on these scenarios:
Following central government guidance, our pensions administration is to be
delivered by an outside agency. Our procedures for new recruits are being
changed to include suitable wording to allow us to forward details to this
new data controller (who have already registered full notifications with
the OIC - I checked).
We need to obtain explicit consent to transfer electronic and manual data
to the new service provider from existing employees - do the new pension
providers also have to obtain permission from staff to process their data?
Apparently, this service provider 'has had access to our data for several
years (a decision made by Cabinet Office)'. Can anyone throw any light on
this?
Secondly, we are about to change our Occupational Health provider - I have
found the guidelines available from the Faculty of Occupational Medicine
and the draft OIC Code of Practice on employer/employee relationships most
helpful.
Although obtaining explicit consent from new recruits to forward data to
and receive information back from the medical provider about their fitness
to work in a range of situations may be relatively straightforward, it will
be necessary to obtain consent from existing staff explaining how any data
will be used and in what situations.
Has anyone had to cope with the scenario where an existing employee refuses
permission to process data? We could be in a position where they could be
making their condition progressively worse whilst we as their employer
could not exercise our 'duty of care' in establishing the cause of the
illness and attempting to make improvements in work patterns/conditions to
alleviate the situation.
Any comments/suggestions welcome,
rgds,
Susan Snell
Archivist
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