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Data Protection Action Plan
Action |
Comments |
Start Date |
End Date |
Responsible |
Status |
Explore ways of recording that staff have read policies and procedures |
System is currently being explored which would allow for recording |
01/08/2021 |
01/10/2022 |
Angela Woodhouse |
underway |
Job descriptions for MG, AW, AC, |
Partially completed due to restructure in the Corporate Insight Communities and Governance Team, new job descriptions have been drafted as part of this process, amends are required to senior officers to show SIRO, DPO status |
01/12/2021 |
30/01/2022 |
Angela Woodhouse |
underway |
Review Logs to ensure best practice - Rights log (SAR). Infor sharing, DPIA and Data Breach need to be reviewed. |
Logs have been reviewed however a system is now being explored which would allow for more accurate and efficient recording than spreadsheets |
01/10/2021 |
30/03/2022 |
Anna Collier/Lauren Connett |
underway |
Undertake programme of information audits |
Postponed and new date provided to coincide with new Senior Information Governance Officer |
01/03/2022 |
30/09/2022 |
Senior Information Governance Officer |
Planned |
Redesign privacy notice |
Design of Privacy Notices should consider: User testing, Electronic and hard-copies, using a combination of appropriate techniques, such as a layered approach, icons and mobile and smart device functionalities. |
01/10/2021 |
30/03/2022 |
Anna Collier/Lauren Connett |
underway |
Audit Privacy Notices |
Privacy Notices should be held in a structured way, including log of former Privacy notices. Review use of consents |
01/10/2021 |
30/03/2022 |
Anna Collier |
underway |
Develop regular programmed points of review of the ROPA in line with audits and survey of officers |
postponed and new date provided to coincide with new Senior Information Governance Officer |
01/03/2022 |
30/09/2022 |
Senior Information Governance Officer |
postponed |
Review Procurement and Data Protection risks |
external advice being sought on the level of risk vs resource to undertake work |
TBC |
TBC |
Anna Collier |
TBC |
Develop information Risk Register |
external advice being sought to support undertaking the development of a best practice risk register |
01/09/2021 |
30/11/2021 |
Anna Collier |
Planned |
Project documentation should be updated to include reference to DPIAs |
Initially postponed and new date provided to coincide with new Senior Information Governance Officer |
01/10/2021 |
TBC |
Gary Hunter |
underway |
Publish DPIAs on website |
|
17/11/2021 |
31/12/2021 |
Lauren Connett |
underway |
*introduce programme of data quality reviews |
There was not sufficient capacity to introduce data quality reviews. New staff have been recruited into the data analytics function and will be undertaking training following which a programme of reviews will be introduced |
01/04/2022 |
ongoing |
Anna Collier |
postponed |
Retention schedule review |
postponed and new date provided to coincide with new Senior Information Governance Officer |
01/03/2022 |
30/09/2022 |
Senior Information Governance Officer |
postponed |
Introduce retention review programme |
postponed and new date provided to coincide with new Senior Information Governance Officer |
30/09/2022 |
|
Anna Collier |
postponed |
Develop a social media policy |
|
TBC |
TBC |
julie Maddocks/julie may |
Planned |
Clear desk policy |
To be implemented when return to office scheduled |
01/10/2021 |
TBC |
|
|
develop page on website to provide to residents in cases of breach or if have privacy concerns |
|
TBC |
TBC |
Gary Hunter |
Planned |
develop advice sheet to provide to residents in cases of breach or if have privacy concerns |
|
TBC |
TBC |
Angela Woodhouse/Julie Maddocks |
Planned |
ensure DP and Information management is routinely on audit plan |
|
TBC |
TBC |
Angela Woodhouse/Rich Clarke |
Planned |
Implement CCTV Review |
|
01/12/2021 |
31/03/2020 |
Anna Collier/Lauren Connett |
Planned |
Implement updated policies |
|
01/11/2021 |
31/01/2022 |
Anna Collier |
underway |
Add review of access to systems to Information Management Board |
Departments have committed to regular review but wider monitor of access to systems is required |
01/01/2022 |
ongoing |
Julie May/Anna Collier |
Planned |