I think good practice is that the receiving organisation deals with the
request, but liaises with the sharing organisations to make sure
everyone is happy.
Donald Henderson
Information Compliance Manager
Perth and Kinross Council
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Michelle Peel
Sent: 27 June 2011 15:32
To: [log in to unmask]
Subject: [data-protection] Data Subject Access Request for shared data
Hi,
I know it's only Monday and not Friday, but it's very hot and my brain
is fried!!!
I'm checking over a template Data Sharing Agreement and amking sure it's
got everything in that the ICO Code of Practice recommends, and am
trying to get my head round what happens in the case of a Data Subject
Access Request to an organisation which holds data which has been shared
with them by the original data controller!
The guidance states that "one staff member or organisation takes overall
responsibility for ensuring that the individual can gain access to all
the shared data easily". With the ContactPoint project, the Local
Authority was joint data controller with HM Government, and any data
subject access requests relating to ContactPoint were to be directed to
the LA - is this how the ICO intends any requests concerning shared data
to be dealt with?
I'm doubting myself because if that were the case, surely the guidance
would state that all DSARs should be dealt with by the originating
organisation/original data controller?!
Any help would be gratefully appreciated by my addled brain!
Thanks,
Michelle Peel
CYPS Information Governance Officer
Trafford Council
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