information sharing sheila logan information commissioner’s office employability partnership event...
TRANSCRIPT
Information Sharing
Sheila LoganInformation Commissioner’s Office
Employability Partnership EventGlasgow
13 August 2009
Information Sharing
Information Sharing
• An overview of the benefits and risks of information sharing.
• Sections of the Data Protection Act
relevant to the sharing of personal information and the ICO Framework Code of Practice.
Impact on individuals
Information sharing – Benefits
• Multi-agency co-operation.
• Personalisation of services.
• Crime reduction partnerships.
• Anti-fraud activity.
• Convenience – one stop shop.
Information sharing -Risks
• Lack of understanding. How and why information is being shared?
• What are the consequences?• Difficulty exercising rights- where do you
go?• Concerns over sensitive information.• Lack of responsibility.• Different priorities.
ICO Guidance
The ICO Framework for Information Sharing
• The Framework breaks down compliance into easy steps and helps organisations develop consistent standards.
• The Framework looks at retention of shared information, security, access and fair processing notices.
First Principle (key principle)
• Personal data shall be processed fairly and lawfully – Schedule 2 condition;
• Sensitive personal data – Schedule 2 and 3 conditions.
Seventh Principle (security)
“Appropriate technical and organisational
measures shall be taken against
unauthorised or unlawful processing of
personal data and against accidental loss
or destruction of, or damage to, personal
data.”
Information sharing in practice
• Define why information is to be shared• Clarifying legal powers and proportionality• Ensure fair processing• Manage information sharing
− Identify who is responsible− Procedure− Decide what information is required, how it is checked for
accuracy, who needs to see it, how long it is retained for, who provides access, etc.
− Management controls to ensure above is followed− Audit− Review regularly
Information Sharing in Practice
Underlying principle –
Is the Information sharing about:
discharging essential services which you
are under a duty to provide,
OR
assisting individuals in securing additional
Services which may be of benefit to them?
Information Sharing in Practice
• Difficulties and PerceptionThe DPA 1998 does not prohibit information sharing in circumstances where this is permitted.
• Problems are often to be found in governing legislation
Are legal powers regimes sufficiently robust?
New government strategies without statutory backing.
Thinking changes rapidly but legislative process is slow.
Information sharing in practice
• Core measures to protect personal information
• Making data protection the foundation of good business practice.
• Culture that values and protects personal information.
• Balanced and considered policy making.
• Assessment of proportionality and risk.
• Minimal information.
Information sharing in practice
• Investment
• Accountability
• Scrutiny
• Effective Regulation
Appropriate Information Sharing!
www.ico.gov.uk