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Compliance for Local Councils in a Time of TransitionCase Studies Shauna Dunlop NI Group Manager Information Commissioner’s Office
Outline • Case Studies • Group Work • Guidance • Feedback • Q & A
Case Study 1 - Data Sharing • An existing data sharing protocol exists between Councils due to form a new Super Council. A routine audit/check reveals an issue with an exercise involving the sharing of a significant amount of personal data. It is possible that the information has also been forwarded to an employee’s personal email account. The employee is facing a possible redundancy and it is known the employee may be in the process of setting up their own business. • What are the data protection considerations? • What steps need to be addressed from an information governance perspective?
Case Study 2 – Personal Data/Staff • A number of requests have been received by an individual Council asking for information about a number of recently appointed senior staff, including the new Super Council Chief Executive. Some of the requests which are largely similar do ask for salary details of an entire Department as well as the salaries of staff who have been made redundant over the last 2 years. • Detail the legislative considerations of this request • What issues need to be taken into consideration?
Case Study 3 – Records Management • A number of Councils preparing for the new Super Council status as part of a records management exercise have developed a draft records management policy. The exercise has identified that a number of file naming conventions are currently being utilised not only across individual Councils but also across Departments. In addition, it has become evident that staff training and understanding with regard to ‘records’ is varied, particularly in relation to security and access controls to various digital as well as manual systems. • Identify the potential information governance risks • What steps could be taken to address the situation?
Case Study 4 –Transfer of Staff and Functions • Some Council premises will be vacated as individual Councils form a new Super Council. In addition some Departments will be restructured which will require staff to move into other buildings. As well as this, some teams will be restructured to accommodate new and temporary staff. • Discuss the requirements for security with regard to data protection during this period • What issues need to be considered and how will they be addressed?
Case Study 5 – Corporate Governance • It is April 2nd 2015 and Stephen Nolan has requested an interview with the new Super Council Chief Executive. It has been reported in the media that a major data breach has occurred within the new Super Council. The media have reported that details of over 10,000 local residents have been uploaded to the internet ‘exposing’ the corporate governance failures of local authorities. The story alleges that the information was discovered on a laptop which was bought by a member of the public on an online auction site. • Review the issues that need to be considered and prepare a brief for the Chief Executive for the interview
Case Study 6 – Information Goverance • It is April 2nd 2015 and the Chief Executive has received a hand written letter from a member of the public thanking the Council for all the work that has been done in the lead up to the new Super Council arrangements. It is clear in the letter she feels confident about the issues that affect her personally. She outlines what information she received and how it was communicated. She feels reassured and has a high level of trust in the new organisation. • Discuss the information governance communication activities • planned and underway within your organisation. Review this • in light of requirements under Data Protection and Freedom of • Information.
Q & A Conclusions
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