The militates for correct and regular audits held by a mixture of external
and internal practitioners to determine that documentation exists and to
verify its existence.
This is starting to be part of the set of benefits our own clients see from
engaging a specialist like my own organisation and others on this list to
conduct such an audit. Frankly it doesn't matter WHO does it. It matters
THAT it is done.
Tim Trent - Consultant
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-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Ian Welton
Sent: Wednesday, February 18, 2004 1:45 PM
To: [log in to unmask]
Subject: Re: [data-protection] Where next?
Broom, Doreen on Wednesday, February 18, 2004 at 11:04 AM said:-
> She should make a SAR....I would have thought it wrong for the
> boyfriend to make the check coming from the point of view that just
> because he may have easy access to such a database
> - perhaps the Police have to make declarations of any associations and
> any check is carried out by a named officer ........but there
> again....Perhaps one of our police colleagues can clarify..........
I would not necessarily agree that she should make a SAR. If people did
that on every occasion they had any doubt about anything, trust could no
longer exist. Determining if a SAR is necessary will be an item for the
individual to determine and will be affected to many personal factors.
Strangely enough, Shelagh Gaskill appeared in an item on the TV news the
other night (TV makeup and all), relating to the Soham case. The news item
in many ways, related to the retention of information and vetting as well as
discussing a national police intelligence system and access to that by the
CRB.
I guess that in areas where problems are more likely to arise, people prefer
to remove the human variable, and create a more static and rigid framework
which may then be reviewed and changed when something goes wrong. After all
an individual does not lose any credibility if an error is caused by a
system (the new red tape), as personal judgement may be divorced from the
problem. Trust in the system is damaged, but I do not suppose that is
perceived as a personal thing and so is of little immediate consequence.
Perhaps people can also be less careful when making those types of
decisions, as they may be forgotten unless they are reviewed following any
error and then the framework is tightened up. That situation may be visible
to DP practitioners when attempting to have system operating procedures or
internal codes of practice reviewed or/and identifying the current system
owner/manager for high risk systems. Much ducking and weaving - leaving the
system to cope and answer any questions.
DP is really in for some trying times where an error is perceived as
systemic. Rather than enquiries about those decisions being directed to the
individual(s) making them there will probably be a tendency to ask DP.
After all DP are responsible for all of the system retention schedules
because of the principles are they not! Or is it that the relevant system
managers are responsible and merely use DP as a shield in order to remain
untainted? Elements of trust intruding in reverse!
The only protection possible for DP seems to be to ensure the relevant
documentation contains all the necessary information and is reviewed at
appropriate intervals.
Ian W
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