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Hi
I think you may be overthinking :-) If performance stats are required to allow you to allocate resources appropriately in order to ensure that you can deliver your public task, then I think it falls as part of that public task. You should
consider the minimum amount of data necessary to complete that task (and therefore pass to the contractor), so will stats suffice for the contractor’s work for example, but it can be justified.
If you prefer, you could consider the wellbeing powers bit of the Local Government Act 2000 as revs and bens fits neatly within
”promotion or improvement of the economic well-being of their area”, but I
believe a certain amount of performance monitoring/management information falls within the individual public tasks, otherwise we’d never be able to plan service delivery.
Victoria Blyth
Information Strategy Manager
Information Management Team
London Borough of Barnet, North London Business Park, Oakleigh Road South, London N11 1NP
Tel: 020 8359 2015
please consider the environment - do you really need to print this email?
Barnet’s Information Management Policies are available on the intranet
here and council website here
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]]
On Behalf Of Sparks, Alison
Sent: 13 April 2018 14:04
To: [log in to unmask]
Subject: [data-protection] Performance Stats
Hi,
Can anyone help please? We process Council tax and Benefits as part of our public task. We have a contract and ISA with a processor to use the data to produce performance management reports for us so that we can allocate resources appropriately.
Post May I cannot see how this can continue without the consent of data subjects as it is outside the original lawful basis for which we collected the data and I don’t think I can include performance stats as part of our public task really.
At the very least we would need to tell people on our Privacy Notice that we share their data with this other company for performance management as the processor is not actually doing anything to process the claims, just produce reports
for us.
I’ve been thinking about it for most of the day and can’t see how we can continue to allow them to process the Council tax and benefit data just to produce reports for us – as I can’t fit this into a lawful basis, apart from consent, which
of course they could withdraw at any time if they consent in the first place. Have I missed something or just overthinking?
Any thoughts gratefully received.
Alison Sparks
Information Management Team
Internal Audit and Information Governance
East Lindsey District Council,
Room 115, Tedder Hall, Manby Park, Manby
Louth, Lincolnshire, LN11 8UP
Tel: 01507 613409
E: information.mangement@e-lindsey.gov.uk
Website: www.e-lindsey.gov.uk
'Lincolnshire's Coastal District'
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