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There's no case law AFAIK. What there is is the evidence in Undertakings and CMP notices of an increasing expectation from the ICO that all "relevant" staff received training. Failure to have achieved this is very likely to be an aggravating factor.
 
There's a strong argument that all "relevant" staff will often mean "all staff", especially in an org that porcessess large amounts of personal data, and/or particularly sensitive personal data.
 

Jonathan Baines
Legal and Democratic Services
Buckinghamshire County Council
01296 383681



From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Trevor Pearce
Sent: Friday 03 August 2012 12:33
To: [log in to unmask]
Subject: [data-protection] Staff Training

I know that the 7th commandment of the DPA is that “appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.”

 

We recently received some marketing gumph asserting that we have to train all of our staff in dp awareness and show that they have passed the training in order to comply with the law. I have confidentally asserted that this is not the case. But does anyone know of any case law that establishes that all staff must receive and complete data protection awareness training to comply with the law?

 

--

 

From: Trevor Pearce

Deputy Academic Registrar (Academic Services)

 


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