Data processing and impact assessments
Our Ref: Our Ref: NY8568 - Date: 11.07.2023
Our Ref: NY8568
FREEDOM OF INFORMATION REQUEST REFERENCE NO: NY8568
I write in connection with your request for information that was received by the Office of the Police, Fire and Crime Commissioner for North Yorkshire (OPFCC) on 15 June 2023.
I note you seek access to the following information:
I am writing to make a formal request for information under the provisions of the Freedom of Information Act 2000. I kindly request that you provide me with the following information:
- A copy of your organisation’s Records of Processing Activity (ROPA) as defined in Article 30 of the UK General Data Protection Regulation (UK GDPR).
- A copy of all legitimate interest assessments conducted by your organisation where you rely on Article 6(1)(f) legitimate interests as your lawful basis for processing.
- A copy of all privacy impact assessments conducted by your organisation.
- A copy of all data protection impact assessments conducted by your organisation.
- A copy of all international transfer risk assessments conducted by your organisation.
- A recent copy of your organisation’s data protection compliance assessment using the Information Commissioner’s Office (ICO)’s accountability framework template. If you are using your own standards to monitor compliance with the Data Protection 2018, please provide me with copy of it.
- A copy of your organization’s data protection policy.
- A copy of your organization’s subject access request policy, procedures, and processes, including any guidance material such as folder structure, naming conventions, and redaction guides.
- A copy of your organisation’s privacy notices, including but not limited to employees, customers, ministers, special advisors (SPADs), complaints, NEDS, visitors, and CCTV.
- A copy of your organisation’s due diligence questions for vendor management such as independent data controllers or processors.
Extent of Searches to Locate Information
To locate the information relevant to your request searches were conducted within the OPFCC.
I am not obliged to provide you with a response to your request pursuant to Section 12(1) of the Freedom of Information Act 2000 (the Act). Please note that when one part of your request falls under Section 12, we are not obliged to review the rest of the questions and the whole request is therefore exempt.
Section 12(1) applies to your request as the cost of complying with your request is above the amount to which we are legally required to respond i.e. the cost of identifying and retrieving any relevant information exceeds the ‘appropriate level’ as stated in the Freedom of Information (Appropriate Limit and Fees) Regulations 2004.
Due to the nature of our recording systems the information requested, if held, is not in an easily retrievable format.
Our information retrieval process generally relies on a computer ran report which captures any information recorded upon the surface of a record or within specified fields. Where relevant information is held deeper in the record, or outside of a specified field, a manual assessment is usually required to retrieve that information.
Pursuant to Section 17(5) of the Freedom of Information Act this letter acts as a Refusal Notice.
Pursuant to Section 16 of the Act I am required to offer you advice and assistance with regarding to refining your request to within the ‘appropriate limit’ (time/cost limit).
A more general, less detailed request in relation to the information you require (such as a request for a summary of documents for example), would enable us to review your resubmitted request if you choose to resubmit and assess whether or not a response could be provided accordingly. If you wish to discuss this please do not hesitate to contact me.
Please note that systems used for recording information are not generic, nor are the procedures used locally in capturing the data. It should be noted therefore that the OPFCC’s response to your questions should not be used for comparison purposes with any other responses you may receive.
Your attention is drawn to the attached sheet which details your right of complaint.
If you have any queries concerning this request, please contact me quoting the reference number above.
Office of the Police, Fire and Crime Commissioner, North Yorkshire