The breakdown and your blog post are greatly appreciated Jon. We have been applying this already to some extent, but also tend to suggest to folk that they take pragmatic approach. If they have to have a process based around 4 weeks to handle February, then that same process fits into every other month too. You don't get prizes for being early, but the consistency will make it more efficient in the long run and less stress all around.
To some extent my frustration is not so much the change but the fact that it is still based on a regulation from some time ago, when working days were considered to be any day other than public holidays, Saturdays and Sundays. It is not black and white anymore (by a long stretch) and still fails to deal with sectors that may have other non-working days (e.g. schools) ... though I appreciate that standardisation is needed especially when it will be called upon within other regs.
The guidance from ICO on extensions varies depending on who you speak with, and I am now facing another round of schools saying that they will respond on the next working day, making that the first full day of teaching (so forgetting that some staff will be in during the holidays and there may be Inset days where pretty much all staff will be in).
On a sunnier note, on my last chat to the ICO helpline the agent did close the call saying that if we can see a gap in the legislation, then we can always approach our MP to raise the matter. You never know ... it can't hurt to ask.
Tony Sheppard CIPP/E
--
Head of Services and Operations
GDPR in Schools
-----Original Message-----
From: This list is for those interested in Data Protection issues <[log in to unmask]> On Behalf Of Jon Baines
Sent: 14 August 2019 16:45
To: [log in to unmask]
Subject: Re: [data-protection] starting the clock - SARs
It does deal with the period of "a week" but the same principle applies to "a month". In effect, one takes the day of the event (in our case, the receipt of a SAR), starts the clock at 23:59 that day (say, a Monday), and counts forward to 23:59 on the next Monday.
Jon
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
All archives of messages are stored permanently and are
available to the world wide web community at large at
http://www.jiscmail.ac.uk/lists/data-protection.html
If you wish to leave this list please send the command
leave data-protection to [log in to unmask] All user commands can be found at https://www.jiscmail.ac.uk/help/subscribers/subscribercommands.html
Any queries about sending or receiving messages please send to the list owner
[log in to unmask]
Full help Desk - please email [log in to unmask] describing your needs
To receive these emails in HTML format send the command:
SET data-protection HTML to [log in to unmask]
(all commands go to [log in to unmask] not the list please)
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
All archives of messages are stored permanently and are
available to the world wide web community at large at
http://www.jiscmail.ac.uk/lists/data-protection.html
If you wish to leave this list please send the command
leave data-protection to [log in to unmask]
All user commands can be found at https://www.jiscmail.ac.uk/help/subscribers/subscribercommands.html
Any queries about sending or receiving messages please send to the list owner
[log in to unmask]
Full help Desk - please email [log in to unmask] describing your needs
To receive these emails in HTML format send the command:
SET data-protection HTML to [log in to unmask]
(all commands go to [log in to unmask] not the list please)
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
