Thanks for your response.
I was more thinking along the lines of just because two items may be in the public domain, is it right from a DPA perspective to decide to link them together and publish them? ie,
1) Job titles and salaries for senior officers £50k - £150K are to be published by law.
2) Names of the Senior Officers are likely to be released to an FOI request.
Link these together and you are able publish the name and salary detail. This seems to be the ICO guidance in response to the 'senior salary transparency guidance'. Are there any issues you would look at from a data protection perspective apart fair processing notice etc?
Cheers
Steve
______________________________________________________________________________________________________________________
Stephen Cotterill
Procurement & Technical Officer x3296
Broxtowe Borough Council
Resources Directorate
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Lynn Wyeth
Sent: 13 January 2011 09:19
To: [log in to unmask]
Subject: [data-protection] Release of personal data
It's not being published under the new Gvt's transparency agenda though is it Steve, it's the law under Regulation 4 of the Accounts and Audit (Amendment Number 2) (England) Regulations 2009 (SI 2009 No. 3322) which introduced a legal requirement for reporting remuneration of senior employees.
As I understand it we have to publish the following:
individual data on all senior employees earning more than £150,000 by job title and name individual data on all senior employees earnings between £50,000 and £150,000 by job title only banded data on all other employees earning over £50,000.
The ICO guidance quoted in those articles fails to acknowledge that this requirement is now in place, but that could be selective cutting and pasting on behalf of that website. I'm sure if you asked the ICO they would quote the Accounts and Audit (Amendment Number 2) (England) Regulations at you to say you have to release those names over £150k now.
We are already publishing names of those earning above £150k as required by this law. p47 of http://www.leicester.gov.uk/accounts/Draft%20Statement%20of%20Accounts%202009-10.pdf
Lynn
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