Within RNN Group, the IG team instigates DSAR searches, staff and departments act on instruction from them, normally this is directed to the nominated person (or admin team) within the department concerned in the first instance, our initial data discovery here (for all records) covers:
Each year's educational records
Each course's details
Tutor records via curriculum
Student finance
Each support plan/ALS records
Health & Safety records
Quality records
Examinations records
Safeguarding records
Marketing records
Email discovery
Human Resources (employees only)
I don't get involved routinely with DSAR's but if it was something that involved the nominated person above (or a member of the IG team) then I would escalate this to the senior leadership team member for that area. No formal training is provided as the IG team act as advisory and instructs searchers accordingly.
Hope this helps.
Ian Headley
Data Protection Officer
RNN Group
From: This list is for those interested in Data Protection issues <[log in to unmask]> On Behalf Of Kat Kuzmin
Sent: 03 February 2020 09:12
To: [log in to unmask]
Subject: [data-protection] DSAR searchers
Sensitivity: Confidential
Happy Monday all!
There does not appear to be much guidance around who is authorised to conduct the initial searches for an access request. It may only boil down to "it's a decision that rests with the organisation." However, how are others deciding who is authorised to perform searchers for access requests?
Do others ask the respective head of department to retrieve the appropriate information? i.e. Head of IT to independently to perform searchers from relevant email accounts. What if the access request relates to the direct party that is performing the searchers? i.e. subject has a grievance with head of department.
Do you have the DPO be involved in every search that is carried out? Do you carry out DSAR training before anyone can conduct searchers to provide evidence of competence/accountability?
This is for organisations that do not have unlimited budgets to employ individuals to specifically carry out DSAR's either...
Kat Kuzmin
Data & Reporting Manager/DPO
HSDC
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Havant Campus: New Road, Havant, Hampshire, PO9 1QL
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